The Safe Cosmetics Act 2010

The Safe Cosmetics Act of 2010 (SCA 2010), now before the House of Representatives, is an inappropriate and seriously flawed attempt to make cosmetics safer. You can read the full text here. The thinking behind it is identical to a bill that was proposed (and defeated on March 1st this year) in Colorado (see Tunnel vision). Both are the brainchild of a group including the Campaign for Safe Cosmetics (SFSC) and the Environmental Working Group (EWG) which are in turn linked to the Skin Deep database. SCA 2010 is being opposed by groups representing small businesses such as Opposesca.com, the Indie Beauty Network and Personal Care Truth which also reflects the views of many cosmetic chemists. A petition opposing SCA 2010 can be found here.

SCA 2010 is unscientific, unworkable, and if passed as is, would likely cause widespread job loss in the cosmetics industry. Far from being a step in the right direction, it would be a leap into regulatory chaos, as well as targeting small businesses and natural products.

Yes, cosmetics could and should be safer, and cosmetics labeling in the USA does need more transparency. Safety can always be improved in any field, especially in the light of new scientific data, but SCA 2010 over-reaches what is needed to such an extent that, with the possible exception of distilled water, I cannot think of any cosmetic ingredient that would be acceptable under its terms.

These require that there is “data demonstrating that exposure to all sources of the ingredient or cosmetic present not more than 1 in a million risk for any adverse effect in the population of concern”. Unfortunately, “population of concern” is not defined, but SCA 2010 further states that, in establishing a safety standard, “no harm will be caused by aggregate exposure for a member of a vulnerable population to that ingredient or cosmetic.” “Vulnerable populations” are defined, and include “pregnant women, infants, children, the elderly, and people with compromised immune systems.” Would “infants” include pre-term babies? Would “people with compromised immune systems” include those who do not get sufficient sleep, or who suffer from frequent colds? Much of the wording of the bill is vague and open to many possible interpretations.

olives“Ingredient” includes every substance present in an ingredient “at levels above technically feasible detection limits.” This last phrase is not defined, but it could be as low as one part per billion (ppb, 0.0000001%) or one part per trillion (ppt, 0.0000000001%). SCA 2010 specifically mentions contaminants, and in foods and beverages they are commonly measured at these levels.

Most essential oils contain about 100 constituents. The above data – for example no more than 1 in a million risk – must be demonstrable for each one of these constituents. Otherwise, the essential oil may not be acceptable in cosmetics, according to the terms of the bill. I can think of of no substance, natural or synthetic, that is known to cause no adverse reaction of any kind in less than 1 in a million people. In human tests for skin reactions, there are sometimes data covering tens of thousands of patch tests. But, that’s still a long way from a million, and there is no cosmetic ingredient that, if patch tested on one million people, would cause no more than one reaction. Except for distilled water perhaps.

“Any adverse effect” is not defined, but is not as simple as it might seem. Linalool, for example, has caused CNS depression when inhaled by animals. (Alcohol is the classic CNS depressant – in large enough amounts, it causes loss of muscular control, slurred speech, stupor and other effects.) Linalool is one of the most common constituents of fragrant herbs and flowers, inhalation of which could therefore be regarded as hazardous under the vague terms of SCA 2010. In reality, linalool has no more than a mild calming, anti-anxiety effect when inhaled by humans. It’s one of the main constituents of lavender oil.

The issue of dose and concentration is not given much consideration. “The Secretary shall presume that any ingredient or cosmetic that induces cancer or birth defects or has reproductive or developmental toxicity when ingested by, inhaled by, or dermally applied to a human or an animal has failed to meet the safety standard.” This is a complete reinvention of the science of toxicology, which up until now has been based on the principle of dose and of threshold levels. Above certain amounts toxicity may occur, below them it will not. This is why there are permissible levels for substances such as hydrocyanic acid (“cyanide”, restricted to 1 ppm) which naturally occurs in some foods.

There’s also the question of the interaction between the constituents of a natural substance. Basil herb, for example, contains two known carcinogens – estragole and methyleugenol. Pesto is a particularly concentrated form of basil, yet the WHO has determined that the amounts in basil/pesto are so small that they present no risk to humans. Since that ruling, research has been published demonstrating that basil herb contains anticarcinogenic substances that counter any potential toxicity of the two carcinogens, and is itself anticarcinogenic (Alhusainy et al 2010, Dasgupta et al 2004, Jeurissen et al 2008). Some basil essential oils have been shown to have anticarcinogenic effects (Aruna & Sivaramakrishnan 1996, Manosroi et al 2005).

Probable or known human carcinogens, such as acetaldehyde and benzo[a]pyrene (BaP) are ubiquitous in fruits, vegetables, dairy products, meat and fish at low ppb. I’m not saying this is a good thing, I’m just saying it’s a fact, and these foods are not regarded as dangerous, because the toxins are present in such minuscule amounts. BaP is one of the many carcinogens found in cigarette smoke, but it is also found in American drinking water at 0.2-2.0 ppb, and in olive oil at about 3 ppb. Olive oil is actually anticarcinogenic, because of its content of antioxidant polyphenols, squalene, beta-sitosterol and linoleic acid (Sotiroudis & Kyrtopoulos 2008). It’s the same story with fruits and vegetables – they are generally anticarcinogenic due to a very much higher content of antitoxic substances.

Many essential oils, herb extracts and foods contain tiny amounts of single constituents that alone, and in substantial amounts, are known to be toxic, but the parent natural substance is not toxic. However, this scenario is not taken into consideration by the CFSC or EWG. These organizations are, wittingly or unwittingly, campaigning to have natural substances banned from use in cosmetics because of their “tunnel vision”  and “parts per billion” approach to safety.

The thinking behind the wording of SCA 2010 is naive because there is an assumption that substances are either “safe” or “toxic”, and that if we simply eliminate the toxic ones from personal care products, the world will be a better place. It may seem like an excellent idea, but once you start talking about parts per million or lower, it is unnecessary and unrealistic. Not even foods are regulated to that degree, and our exposure to foods is far greater than our exposure to cosmetics.

SCA 2010 requires that every constituent or trace contaminant of every ingredient be listed on the product label. This arguably discriminates against natural products, since their ingredient lists would have to include hundreds of substances, if they could be proved to be safe under the terms of the bill, and if there was some way of actually listing that many ingredients on a label. A product containing what would normally be regarded as five ingredients – olive oil, blue chamomile extract, and essential oils of orange, rose and vetiver – would require an ingredient list looking something like this:

oleic acid, palmitic acid, stearic acid, linoleic acid, linolenic acid, squalene, hydroxytyrosol, tyrosol, oleuropein, ligstroside, elenolic acid, acetoxy-pinoresenol, oleocanthal, alpha-tocopherol, herniarin, hyperoside, umbelliferone, methylumbelliferone, caffeic acid, chlorogenic acid, quercetin, rutin, flavanone, isorhamnetin, quercimeritin, anthemic acid, choline, triacontane, patuletin, patulitrin, apigetrin, apigenin-7-glucoside, apigenin-7-apiosylglucoside, luteolin-7-glucoside, apigetrin-7-acetylglucoside, luteolin-4-glucoside, luteolin, patuletin, matricin, matricarin, galacturonic acid, d-limonene, citronellol, geraniol, myrcene, linalool, alpha-pinene, sabinene, beta-phellandrene, geranial, neral, decanal, citronellal, (Z)-beta-ocimene, beta-pinene, valencene, beta-elemene, terpinolene, dodecanal, gamma-terpinene, beta-sinensal, alpha-sinensal, delta-cadinene, alpha-copaene, gamma-muurolene, nerol, delta-3-carene, (Z)-3-hexenol, perillaldehyde, octanol, cis-sabinene hydrate, undecanal, nonadecane, heneicosane, 1-nonadecene, 2-phenylethanol, (E)-beta-ocimene, methyleugenol, eugenol, 1-heptadecene, eicosane, trans-linalool oxide, beta-caryophyllene, 1-tricosene, alpha-terpineol, alpha-farnesene, farnesyl acetate, citronellyl formate, pentadecane, alpha-guiaiene, benzaldehyde, (Z)-beta-farnesene, terpinen-4-ol, geranyl acetate, isogeranyl acetate, farnesyl propionate, methyl salicylate, citronellyl acetate, hexanol, alpha-humulene, methyl geranate, alpha-terpinene, cis-rose oxide, isogeraniol, beta-bergamotene, delta-2-carene, cis-linalool oxide, octadecane, heptadecane, alpha-phellandrene, cis-rose oxide, beta-maaliene, ethyl benzoate, geranyl acetone, 3-methylbutanol, docosane, 1-heneicosene, para-cymene, 1-eicosene, bourbonene, gamma-cadinene, hexadecane, 1-tricosene, octanal, nerolidol, 2-undecanone, benzyl benzoate, alpha-muurolene, 2-phenylethyl phenylacetate, farnesol, geranyl formate, guaiol, heptanal, allo-ocimene, 1-octadecene, 2-phenylethyl-3-methyl valerate, hexadecanol, hexanal, 3-hexenyl formate, 2-phenylethyl benzoate, khusimol, vetiselinenol, cyclocopacamphan-12-ol (epimer A), alpha-cadinol, alpha-vetivone, beta-vetivenene, beta-eudesmol, beta-vetivone, khusenic acid, beta-vetispirene, gamma-vetivenene, alpha-amorphene, (E)-eudesm-4(15),7-dien-12-ol, beta-calacorene, (Z)-eudesm-6-en-11-ol, gamma-amorphene, ziza-5-en-12-ol, beta-selinene, (Z)-eudesma-6,11-diene, salvial-4(14)-en-1-one, khusinol, cyclocopacamphan-12-ol (epimer B), selina-6-en-4-ol, khusian-ol, delta-amorphene, 1-epicubenol, khusimene, ziza-6(13)-en-3beta-ol, ziza-6(13)-en-3-one, 2-epi-ziza-6(13)-en-3alpha-ol, 12-nor-ziza-6(13)-en-2beta-ol, alpha-vetispirene, eremophila-1(10),7(11)-diene, dimethyl-6,7-bicyclo-[4.4.0]-deca-10-en-one, 10-epi-gamma-eudesmol, alpha-calacorene, (E)-opposita-4(15),7(11)-dien12-ol, prekhusenic acid, 13-nor-eudesma-4,6-dien-11-one, isovalencenol, spirovetiva-1(10),7(11)-diene, 2-epi-ziza-6(13)-en-12-al, (E)-isovalencenal, preziza-7(15)-ene, (Z)-eudesma-6,11-dien-3beta-ol, intermedeol, isoeugenol, isokhusenic acid, elemol, eremophila-1(10),6-dien-12-al, juniper camphor, khusimone, eremophila-1(10),4(15)-dien-2alpha-ol, eremophila-1(10),7(11)-dien-2beta-ol, (Z)-isovalencenal, allo-khusiol, methyl-(E)-eremophila-1(10),7(11)-dien-12-ether, (E)-2-nor-zizaene, (Z)-eudesm-6-en-12-al, funebran-15-al

No contaminants have been shown here, only natural constituents of the five ingredients. Whether this list of 200 chemicals would be useful for consumers is debatable, and it would be one of the shorter lists, since most natural products contain much more than five ingredients. Even single synthetic chemicals are not really single chemicals at all – they also contain some minor and trace constituents. Most fragrance chemicals for example are about 95% pure, the other 5% consisting of “impurities” which of course would have to be listed. So synthetic chemicals are not exempt from this challenge.

This is one of the reasons that a naturally-occurring chemical is not the same as a synthetic one – the impurities present in the synthetic version. Synthetic coumarin, for example, causes skin allergies because of the impurities it contains (Vocanson 2006, 2007). But, SCA 2010 treats all chemicals of the same name as equal, which may be expedient if you are trying to pass legislation, but it’s not really scientific.

SCA 2010 proposes that hundreds of ingredients should be assessed for safety in unrealistically short amounts of time, with no proposal as to what form this assessment process will take, who will undertake the work, and exactly what criteria will be used. The wording of the bill shows very little understanding of either toxicology or cosmetics science. It also assumes that any existing legislation in other countries must be good legislation, when in fact nothing could be further from the truth.

I happen to believe that incremental legislation is generally a good thing. It at least allows for the possibility of public debate, and for finer points to be properly considered. Legislation as sweeping as SCA 2010 will cause chaos in the cosmetics industry, especially since States will be given the option to add further safety standards as they see fit. So, each State could have different standards – a manufacturer’s nightmare, and a pointless provision. Even without it, how any agency could enforce legislation involving hundreds of thousands of existing products, with hundreds of ingredients to consider for each one is mind-boggling.

SCA 2010 will cost unknown millions or billions of dollars which the consumer will ultimately pay for. It will probably have no more than a negligible effect on cosmetics safety, but it poses a serious threat to many businesses especially those making natural products, those supplying natural ingredients, and the farmers that grow the plants they come from.

In health news...SCA 2010 is especially onerous to small businesses (any corporation with a turnover of $7 million or less.) It requires each manufacturer to not only declare every constituent chemical of every ingredient on the label, but to also test each finished cosmetic to ensure that there is not even a trace amount of some toxic chemical that might have been formed during the making of the product. Most small personal care product businesses will not survive if SCA 2010 passes, a fact that may possibly be attractive to larger corporations.

However, the bill has been criticised by Lezlee Westine, President and CEO of the Personal Care Products Council, which represents the larger cosmetics companies. Her statement includes the following: “We are concerned that the Safe Cosmetics Act of 2010 as written is not based on credible and established scientific principles, would put an enormous if not impossible burden on FDA, and would create a mammoth new regulatory structure for cosmetics, parts of which would far exceed that of any other FDA-regulated product category including food or drugs. The measures the bill would mandate are likely unachievable even with the addition of hundreds of additional FDA scientists and millions more in funding and would not make a meaningful contribution to product safety.”

The Skin Deep database, mentioned in the first paragraph, gives an insight into the thinking of the CFSC and EWG. Skin Deep exaggerates toxicity by being selective in its reporting. For example, limonene, the major constituent of citrus essential oils, is flagged as being developmentally toxic in large doses. This is true, since when pregnant mice were fed 2,363 mg/kg limonene by stomach tube on days 7-12 of gestation, there was an increase in the number of fetuses with skeletal anomalies and delayed ossification (Kodama et al 1977).

However, what is not stated by Skin Deep is that in the same report, when pregnant mice were given a lower dose, 591 mg/kg/day, there was no developmental toxicity. The higher dose is equivalent to daily human ingestion of 5.7 oz of limonene, and the lower dose is equivalent to 1.4 oz. If ingestion of 1.4 oz per day for 6 days is known to be non-fetotoxic, then there is no reason to believe that the use of limonene in cosmetics is likely to be in any way hazardous during pregnancy; in fact, quite the opposite (especially since stomach tube feeding generally increases toxicity).

The Skin Deep page on limonene also mentions, under “cancer” that“one or more tests on mammalian cells show positive mutation results.” One reference is given. However, this ignores the fact that eleven other studies found no evidence of mutagenicity or genotoxicity for limonene (Anderson et al 1990, Connor et al 1985, Florin et al 1980, Haworth et al 1983, Myhr et al 1990, Pienta 1980, Sasaki et al 1989, Sekihashi et al 2002, Turner et al 2001, Watabe et al 1980, 1981), and two further studies reported antimutagenic effects (De Oliveira et al 1997, Kim et al 2001). This 13:1 “score” is part of the weight of evidence used to assess risk in toxicology.

Mutagenicity testing is used to identify substances that may be carcinogenic. However, 85% of substances that are not in fact carcinogenic test positive in a least one mutagenicity test (Kirkland et al 2005). These are “false positives”, and present no risk. The one study cited by Skin Deep for limonene is a false positive.

If you want to imply risk, it’s possible to do so simply by being selective about which facts you choose to report. Many small cosmetics manufacturers have become disenchanted with the manipulative ways of the CFSC and EWG. If they were sincere in caring about cosmetics safety they would welcome any pertinent opinions and facts, but they don’t. They either ignore or stridently oppose anything that does not accord with their fear-driven political agenda. It’s a shame, because a few of their concerns are genuine and well-founded, but their focus has become highly distorted.

I urge you to oppose the Safe Cosmetics Act 2010. Here are some steps you can take.

References

Alhusainy W, Paini A, Punt A et al 2010 Identification of nevadensin as an important herb-based constituent inhibiting estragole bioactivation and physiology-based biokinetic modeling of its possible in vivo effect. Toxicology & Applied Pharmacology 245:179-190

Anderson BE, Zeiger E, Shelby MD et al 1990 Chromosome aberration and sister chromatid exchange test results with 42 chemicals. Environmental & Molecular Mutagenesis 16(Suppl. 18):55-137

Aruna K, Sivaramakrishnan VM 1996 Anticarcinogenic effects of the essential oils from cumin, poppy and basil. Phytotherapy Research 10:577-580

Connor TH, Theiss JC, Hanna HA et al 1985 Genotoxicity of organic chemicals frequently found in the air of mobile homes. Toxicology Letters 25:33-40

Dasgupta T, Rao AR, Yadava PK 2004 Chemomodulatory efficacy of basil leaf (Ocimum basilicum) on drug metabolizing and antioxidant enzymes, and on carcinogen-induced skin and forestomach papillomagenesis. Phytomedicine 11:139-151

De Oliveira AC, Ribeiro-Pinto LF, Paumgartten FJ 1997 In vitro inhibition of CYP2B1 monooxygenase by b-myrcene and other monoterpenoid compounds. Toxicology Letters 92:39-46

Florin I, Rutberg L, Curvall M et al 1980 Screening of tobacco smoke constituents for mutagenicity using the Ames test. Toxicology 15:219-232

Haworth S, Lawlor T, Mortelmans K et al 1983 Salmonella mutagenicity test results for 250 chemicals. Environmental Mutagenesis 5:3-38

Jeurissen SM, Punt A, Delatour T et al 2008 Basil extract inhibits the sulfotransferase mediated formation of DNA adducts of the procarcinogen 1′-hydroxyestragole by rat and human liver S9 homogenates and in HepG2 human hepatoma cells. Food & Chemical Toxicology 46:2296-2302

Kim MH, Chung WT, Kim YK et al 2001 The effect of the oil of Agastache rugosa O. Kuntze and three of its components on human cancer cell lines. Journal of Essential Oil Research 13:214-218

Kirkland D, Aardema M, Henderson L et al 2005 Evaluation of the ability of a battery of three in vitro genotoxicity tests to discriminate rodent carcinogens and non-carcinogens I. Sensitivity, specificity and relative predictivity. Mutation Research 584:1-256

Kodama, R, Okubo A, Araki E et al 1977 Studies on d-limonene as a gallstone solubilizer (VII). Effects on development of mouse fetuses and offspring. Oyo Yakuri 13:863-873

Manosroi J, Dhumtanom P, Manosroi A 2005 Anti-proliferative activity of essential oil extracted from Thai medicinal plants on KB and P388 cell lines. Cancer Letters 235:114-120

Myhr B, McGregor D, Bowers L et al 1990 L5178Y Mouse lymphoma cell mutation assay results with 41 compounds. Environmental & Molecular Mutagenesis 16(Suppl 18):138-167

Pienta R J 1980 Evaluation and relevance of the Syrian hamster embryo cell system. Applied Methods in Oncology 3:149-169

Sasaki YF, Imanishi H, Ohta T et al 1989 Modifying effects of components of plant essence on the induction of sister-chromatid exchanges in cultured Chinese hamster ovary cells. Mutation Research 226:103-110

Sekihashi A, Yamamoto A, Matsumura Y et al 2002 Comparative investigation of multiple organs of mice and rats in the comet assay. Mutation Research 517:53-74

Sotiroudis TG, Kyrtopoulos SA 2008 Anticarcinogenic compounds of olive oil and related biomarkers. European Journal of Nutrition 47:69-72

Turner SD, Tinwell H, Piegorsch W et al 2001 The male rat carcinogens limonene and sodium saccharin are not mutagenic to male Big Blue rats. Mutagenesis 16:329-332

Vocanson M, Goujon C, Chabeau G et al 2006 The skin allergenic properties of chemicals may depend on contaminants – evidence from studies on coumarin. International Archives of Allergy & Immunology 140:231-238

Vocanson M, Valeyrie M, Rozières A et al 2007 Lack of evidence for allergenic properties of coumarin in a fragrance allergy mouse model. Contact Dermatitis 57:361-364

Watabe T, Hiratsuka A, Isobe M et al 1980 Metabolism of d-limonene by hepatic microsomes to non-mutagenic epoxides toward Salmonella typhimurium. Biochemical Pharmacology 29:1068-1071

Watabe T, Hiratsuka A, Ozawa N et al 1981 A comparative study on the metabolism of d-limonene and 4-vinylcyclohex-1-ene by hepatic microsomes. Xenobiotica 11(5):333-344

30 comments to The Safe Cosmetics Act 2010

  • Great post, Robert! Your experiences as an aromatherapy pioneer, expert, author and formulator shine beautifully as you illustrate in simple terms why HR 5786 as written is not rationally related to the goal of ensuring safe cosmetics. Thank you for this well considered post, which brings increased clarity to the issues.

  • Fantastic post Robert. Thank you for pointing out the Limonene study. I had not known that a lower level of limonene was not shown to be toxic; only the higher ingestion level study. This bill, as written, goes too deep and too far and will be virtually unenforceable.

  • Thanks so much for the article. As a small business owner this is just overwhelming! Donna Marie, Kayla, Anne-Marie and others are doing so much to help us. We appreciate everything you are all doing to help stop this Act from passing!!!!

  • Very informative article. Your example of how this bill would affect ingredients lists shows how counterproductive this bill would be, not just for businesses, but consumers as well. The unfortunate thing is that many consumers may believe that this bill would make reading and understanding ingredients labels easier on them, but not so. This would be a lose-lose situation.

  • A very thorough and well research report on the cosmetic bill. It’s the best commentary I’ve seen to date. Thank you for sharing this information.

  • Thank you Robert for this well researched and carefully documented post explaining the dangers of The Safe Cosmetics Act of 2010. Your expertise regarding safety and aromatherapy gives your points even more weight. I hope all small businesses will carefully consider this and compare the references of this post to the references being used to justify the regulations being pushed by the EWG and CFSC.

  • Thank you Robert. Really great that you are on the job on this one, which can be very confusing to the average consumer.

  • Mahalo for your informative & thorough explanation of SCA 2010! Yes, we all want safe cosmetics…and food, and clothing & toys,etc! But as you say, as written, this bill is more of a detriment than a help! Mahalo for all your time & hard work!!

  • Thank you for taking the time, Robert, to articulate your thoughts on this very important subject. Now, if we could just get this published via the Associated Press!

    Please support the HSMG Legislative Advocacy Committee to ensure that our voice is heard in Washington, before it’s too late: http://www.soapguild.org/industry/leg-advocacy.php.

    A small contribution of just $25 a month, or whatever each person can afford, will go a long way toward making sure we have the representation we so desperately need right now.

  • Robert, thank you so much for giving me permission to use your blog post on the SCA 2010 as the official blog for the Natural Perfumers Guild. I have been trying to blog about this onerous bill since July 27th, when I signed the petition, but family matters dominated my life, so I couldn’t find time to write. Again, thank you for your kindness and generosity in allowing the Guild to link to your post and use it for our position statement on SCA 2010.

  • Robert,

    Thank you so much for posting this!earlier today I printed all 47 pages of H.R. 5786 you have written very well and it’s easy to understand. Excellent work

  • Jennifer Dobbins

    Thank-you so much Mr. Tisserand. I have always set my ” essential oil standards” by all your wonderful books and information. This bill would utterly destroy my tiny business in handcrafted soaps.

  • Dani Abrahams

    Robert,
    Excellent article. You mention valid points and I agree with you. Where did you find that the “SCA 2010 is especially onerous to small businesses (any corporation with a turnover of $7 million or less?)” On page 12 of the bill it states that companies with gross sales over $1 mill will be charged fees for the new regulations. I’m sure by the wording of the bill all companies will be charged fees pending their gross sales, but from I read companies making over a million will cover the majority of fees.
    Also, who is going to pay for the SCA and who is the “Secretary”? The SDD isn’t accurate and they are the people who will be running the cosmetic regulations? When the SDD rates ingredients a “Zero” with 100% data gap, I call that irresponsible. I would like to see a list of the “Restricted” chemicals as well. I attended a seminar a couple of weeks ago in Denver, CO. The EWG and Colorado Woman’s Lobby spoke. On the list of “Restricted” ingredients for the Denver Bill was Progesterone. You can read more on my facebook page.
    http://www.facebook.com/profile.php?id=557766933#!/pages/Millions-for-TRULY-Natural-Products/134416503237974?ref=ts

    Thank you for your article, I hope the bill doesn’t pass.

  • Even distilled water wouldn’t be safe to use under the “Safe” Cosmetics Act. Sure it’s pure water, but the SCA also considers as an ingredient anything that might leach out of the container into the distilled water. You can’t move water around without using some kind of container, and this law would require you to know what leaches out of the container. Since distilled water is sold in food-grade plastic jugs, likely nothing terribly harmful leaches into it; nevertheless, the law requires that you know this for sure, and how are you going to know unless you send it off and have a battery of tests run on it?

  • Thank you Mr Tisserand.- The experience and the knowledges that you have about essential oil are very important in the aromatherapist world.

    Thanks for alll your Knowledges that give us.

  • Ann Skinner

    Thank you Robert for this very informative report. I am new to aromatherapy, but even I can see this bill wii have nothing but determental effects to the whole natural based industry.Please keep all of us informed of actions like this. Thank you again for all your work.

  • Once again, Robert, you’ve created a stellar article.

    One thing to note, however, in a recent conference call with the Campaign For Safe Cosmetics, Lisa Archer, one of their main representatives stated that constituents of essential oils and oils would not need to be labeled down to their individual compounds. The purpose of the labeling requirements as set forth in the bill are aimed towards synthetic fragrances. However, the bill does not specify this, and I have requested that the language in the bill reflect what Lisa is saying. The wording is not clear in the bill, and so much depends on what the proposed “secretary” sets forth. My question to them was…what happens when this “secretary” is a former CEO of a large cosmetics company and requires a bunch of testing on products–that only large companies can afford to do, thus wiping out the competition from small businesses. Too much power is put in the one person because of the vague language of the bill

  • Thank you Stephanie, and of course those constituents WOULD have to listed the way the bill is currently worded, whatever Lisa Archer may have said. It’s puzzling to me why the EWG would want to give so much power to the FDA, and expect them to regulate hundreds of substances within a two year period, when the EWG has so far done nothing but criticize the FDA and their general lack of urgency in dealing with cosmetic safety issues. But I agree that one of the fundamental flaws in the bill is its vague wording. How can anyone support it when they don’t know what they would be supporting?

  • Susan Sawhill Apito

    Thank you so much Robert. You have presented such an easy to understand argument against this bill I think it may have more impact than just about everything else I have seen written on the subject. The example of your simple, safe, healthy five-ingredient product label speaks volumes. THANK YOU!!

  • Betti

    Thank you Mr. Tisserand. Your articles are always very interesting, useful and helpful

  • Thank you Robert I have passed this link on to others who may be interested. Your book The Art of Aromatherapy 1989 was my first book on Aromatherapy and I still refer to it. I also still use Aromatherapy for Women.

  • Donna Nayel

    Thank you for your expertise, your research, your time and your involvement with this issue! I am in Canada – but I’m sure we are all aware that should this pass in the US the effects on Canada will be similar!

  • EXCELLENT, concise article…THANK YOU!

  • [...] personal care product businesses will not survive if SCA 2010 passes.” [fragrance specialist Robert Tisserand] The lead sponsors of the proposed Safe Cosmetics Act of 2010 (H.R. 5786) are Reps. Jan Schakowsky, [...]

  • Robert, Thankyou for all of your research and allowing this to be printed. I am a very happy client and feel the products I use are 100% safe for me and mine. Too much ‘big brother’ looking over everything can ruin just good plain good sense and using natures own. I do hope Act 2010 does not pass and the government spends money and time on more worthwhile projects. Thankyou

  • Awesome article! Thank you for writing it.

  • hmm. Personally, I don’t buy a cosmetic without checking the SkinDeep website. And I believe the Environmental Working Group does a lot of good work in other areas; fracking, for instance. So why are these groups that I consider reputable throwing the baby out with the bathwater on this issue? That’s the missing link for me. If someone could explain this clearly I’d be grateful.

  • [...] – there’s an absolutely incredible article that explains more specifics about the misleading/missing science behind the bill and details its potential ramifications for labels at this aromatherapy guild page. [...]

  • [...] and the 70 or so constituents of lavender oil should not have to be listed. I have already argued here against the idea that constituents of ingredients should be declared on cosmetic [...]

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