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Ten reasons why you should not support SCA 2011

The Environmental Working Group, who have given birth to this legislation, is an incompetent organization that does not understand the science of toxicology, does not understand natural products, and that takes a biased, negative view of safety, often seeing dangers that do not exist.

  1. SCA 2011 requires that all ingredients of ingredients must be declared on product labels or company websites (where labels are not large enough). This unfairly targets companies that make natural products. A product containing several herb extracts and/or essential oils will have an ingredient list with thousands of ingredients. This will make reading ingredient lists harder for consumers, not easier.
  2. Unlike some other safety regulations, SCA 2011 does not distinguish between a naturally occurring substance (such as an ingredient of a herbal extract) and the intentional addition of a synthetic chemical. The end result of this will be that many herb extracts and essential oils will no longer be permitted as cosmetic ingredients as has already happened in Europe.
  3. SCA 2011 requires that “contaminants” (the word is not defined anywhere in the bill) that are present in a cosmetic at one part per billion or over be declared on the ingredients list. This expectation is naïve, unnecessary and impractical. Even pharmaceuticals are not regulated to such a degree.
  4. SCA 2011 requires a safety standard for cosmetics that is defined as a risk not greater than one in a million. Demonstrating this conclusively would, by definition, require testing on millions of either animals or humans. This is similarly naïve, unnecessary and impractical but if enforced, would mean that there will be no cosmetics, because it is an unreachable standard.
  5. The above safety standard is specifically stated to include all “vulnerable populations” including a sick person with a compromised immune system, someone with asthma, and a newborn infant. Every cosmetic produced has to present zero risk to every human being. However, zero risk is a fantasy of the EWG – it does not exist on planet Earth.
  6. Even though the bill includes a clause about alternatives to animal testing, the stipulations of SCA 2011 for safety testing for carcinogenicity and reproductive toxicity will necessitate the deaths of thousands of animals because there are as yet no viable substitutes for these two toxicity tests.
  7. The massive amount of new testing proposed by SCA 2011, and all the attendant administration will cost billions of dollars. One way or another, this cost will be passed on to consumers. This is not the time to be spending this kind of money on unnecessary legislation.
  8. The amount of checking, testing, listing, re-designing, re-formulating, re-printing and form-filling would be a massive burden to cosmetics companies. Some, both large and small, will go out of business, with attendant job losses.
  9. Labeling regulations are already onerous for any company selling internationally. Since the labeling requirements of SCA 2011 are not in line with those of any other country or region, this will create chaos in the industry.
  10. Although SCA 2011 delegates authority to the FDA, it also allows for any “responsible party” to file a claim that a product may cause serious adverse health effects. This is the EWG giving itself the power to endlessly pursue products or companies that it does not like.

Cosmetics safety regulations in the USA could be improved, but this is not the answer. It is over-reaching, unworkable and unnecessary.

By | 2011-07-04T15:57:01+00:00 July 4th, 2011|Legislation, News|Comments Off on Ten reasons why you should not support SCA 2011

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  1. margie lemons July 4, 2011 at 10:15 pm

    I appreciated seeing your quick and responsible reaction to this proposed legislation, thank you.

  2. Stephanie July 5, 2011 at 5:02 am

    Thank you for the information. What can we do to stop this legislation?

  3. JoAnne Bassett July 5, 2011 at 9:09 am

    Thank you Robert for this alarming clarification. Has everyone gone mad? 1. The lists of ingredients on labels is absurd. The expenses to both government, and the manufacturer is huge. The end result will be increased prices and everyone will lose…

  4. Robert Tisserand July 5, 2011 at 1:31 pm

    A petition to oppose SCA 2011 has just been set up here: http://www.thepetitionsite.com/1/no-2-sca-2011/

  5. Sue Sawhill Apito July 7, 2011 at 4:20 pm

    Facebook page created to discuss:

    https://www.facebook.com/#!/pages/Discuss-the-Safe-Cosmetics-Act-2011-HR2359/134096183338597

    Thank you for your helpful review! Sue

  6. Marlene Mitchell July 8, 2011 at 1:27 pm

    “Dear” Robert :>) This cosmetic act is practically the worst thing that can happen in our Aromatherapy/Herb world. This will be catastrophic. Thanks very much for presenting more valuable insight to this horrrible bill/act. The world does not need this. I understand safety in products, but this is truly overboard. We need to do everything we can to stop this horrible bill/act.

    Many aromatic blessings,
    Marlene Mitchell
    Representative of Western Canada with the
    Alliance of International Aromatherapists

  7. Jen July 17, 2011 at 6:16 pm

    Robert, thank you.

  8. Rebecca Hamilton July 20, 2011 at 5:10 pm

    Dear Robert,

    Firstly, I would like to say that I have read most of your books and I have a great deal of respect for you and for your work. I believe that your viewpoint is valuable and could be of great service to the authors and supporters of the SCA 2011. This bill is still a living document and your constructive critique could still help to shape the bill. In the mean time, please see below for my response to your blog post.

    The Environmental Working Group, who have given birth to this legislation, is an incompetent organization that does not understand the science of toxicology, does not understand natural products, and that takes a biased, negative view of safety, often seeing dangers that do not exist.

    **I can see that you are not in support of the efforts of the EWG, which is your prerogative – however, you should know that they are certainly not the only organization involved in creating this bill. Along with the bill authors, the campaign for safe cosmetics spans a large number of NGO’s with a wide range of expertise. In addition, many cosmetic companies have been involved in shaping the bill to help ensure that there is a balance between cosmetic safety and the health of small businesses.

    1. SCA 2011 requires that all ingredients of ingredients must be declared on product labels or company websites (where labels are not large enough). This unfairly targets companies that make natural products. A product containing several herb extracts and/or essential oils will have an ingredient list with thousands of ingredients. This will make reading ingredient lists harder for consumers, not easier.

    **This is not actually true. This was the case in the 2010 version of the bill, but the 2011 version no longer has that particular requirement. All botanicals can be listed as they are listed now. There may be some rare cases in which specific allergens may need to be listed separately, as is the case in the EU.

    2. Unlike some other safety regulations, SCA 2011 does not distinguish between a naturally occurring substance (such as an ingredient of a herbal extract) and the intentional addition of a synthetic chemical. The end result of this will be that many herb extracts and essential oils will no longer be permitted as cosmetic ingredients as has already happened in Europe.

    **I would be interested to hear which herb extracts and essential oils have been banned from the EU. We currently sell our products, which contain a great number of herb extracts and essential oils, in the EU and we have not yet had to remove any of our ingredients, with the exception of citronella oil. Is this a big concern in the EU? Have there been many natural ingredients banned? If so, which ones?

    3. SCA 2011 requires that “contaminants” (the word is not defined anywhere in the bill) that are present in a cosmetic at one part per billion or over be declared on the ingredients list. This expectation is naïve, unnecessary and impractical. Even pharmaceuticals are not regulated to such a degree.

    **I agree – this restriction on contaminant listing should be redefined. Let’s work with the bill authors to reword this section so that it makes more sense. I would suggest that the contaminant labeling requirements be directly linked to specific contaminants of concern and the levels at which they are deemed impactful.

    4. SCA 2011 requires a safety standard for cosmetics that is defined as a risk not greater than one in a million. Demonstrating this conclusively would, by definition, require testing on millions of either animals or humans. This is similarly naïve, unnecessary and impractical but if enforced, would mean that there will be no cosmetics, because it is an unreachable standard.

    **I believe that there is a bright future for alternative testing. In conversations with the Leaping Bunny Coalition and with PETA, I have found that there is a great deal of movement towards creating viable alternatives and in the very near future we will not need to rely on animal testing for accurate toxicity screening. That being said, how would you reword this section to make the requirements more realistic – The main goal being to create the absolute safest cosmetics possible? The bill authors need realistic feedback from our industry that does not damage the integrity of bill and its goals.

    5. The above safety standard is specifically stated to include all “vulnerable populations” including a sick person with a compromised immune system, someone with asthma, and a newborn infant. Every cosmetic produced has to present zero risk to every human being. However, zero risk is a fantasy of the EWG – it does not exist on planet Earth.

    **I believe that your assessment of this section is different from the intent of the bill. For example, people with asthma or specific allergies are not intended to be considered as immune deficient. As far as being safe for newborn infants, this is largely based on the studies that have shown harmful cosmetic chemicals to be present in the mother’s body. Perhaps this section could be reworded to clarify that cosmetics intended for women of childbearing age or infants need to be held to a higher level of safety.

    6. Even though the bill includes a clause about alternatives to animal testing, the stipulations of SCA 2011 for safety testing for carcinogenicity and reproductive toxicity will necessitate the deaths of thousands of animals because there are as yet no viable substitutes for these two toxicity tests.

    **We could and should work to improve this section of the bill to strengthen its support of more humane testing practices. The alternative toxicology testing research is a world wide effort at present and is rapidly evolving. The EU has already banned the use of animal testing and they are actively seeking alternatives for the carcinogenicity and reproductive toxicity testing. As I wrote above, in vitro testing options are becoming more prevalent and more accurate. The bill does not specify which testing would be required to ensure that ingredients are safe, however, now is the time that we could help push the industry away from animal testing and support the development of safe and humane alternatives. That being said, most other countries do require safety substantiation for all ingredients, this includes the entire EU.

    7. The massive amount of new testing proposed by SCA 2011, and all the attendant administration will cost billions of dollars. One way or another, this cost will be passed on to consumers. This is not the time to be spending this kind of money on unnecessary legislation.

    **Whether or not this legislation is unnecessary is subjective, but please don’t underestimate the hidden costs of unsafe products. The above costs that you are throwing around are based on speculation not fact. You may be surprised at how much of this required testing has already been conducted and if made public could be used to support the safety of many commonly used ingredients. I would also reiterate – most other countries are requiring similar ingredient safety verification, and in fact, this bill would give use the extensive EU safety data which has already to help determine ingredient safety.

    8. The amount of checking, testing, listing, re-designing, re-formulating, re-printing and form-filling would be a massive burden to cosmetics companies. Some, both large and small, will go out of business, with attendant job losses.

    **This legislation exempts small micro-businesses for just that reason. The bill recognizes the administrative burden that the registration process would incur. You are making the assumption that companies would go out of business. I might suggest that the requirements of the bill alone would not be enough to put a healthy company out of business, small or large. These requirements are not substantially different from international registration and testing requirements and our industry is strong enough to shoulder this burden.

    9. Labeling regulations are already onerous for any company selling internationally. Since the labeling requirements of SCA 2011 are not in line with those of any other country or region, this will create chaos in the industry.

    **The US is already completely out of compliance internationally with our current cosmetic labeling laws or lack thereof, so I don’t see how the SCA would create additional chaos. As an international company, we learn to deal with the varying regulations and labeling laws of each of the countries that we work with.

    10. Although SCA 2011 delegates authority to the FDA, it also allows for any “responsible party” to file a claim that a product may cause serious adverse health effects. This is the EWG giving itself the power to endlessly pursue products or companies that it does not like.

    **There is no reason why a responsible party should not be allowed to file a claim if they are concerned that a product may cause serious adverse health effects. It is up to the FDA to determine whether or not that claim is valid – but to deny someone the right to make that claim would be denying freedom of speech.

    Cosmetics safety regulations in the USA could be improved, but this is not the answer. It is over-reaching, unworkable and unnecessary.

    **If you agree that the cosmetic safety regulations could be improved, why not work with the organizations in support of this bill to help make this bill into the improvement that you would like to see in this industry. Nothing is set in stone here. As I wrote before, you could lend your voice toward helping to strengthen and improve this important piece of legislation rather than simply opposing it.

    Thank you for taking the time to read my response. Please feel free to contact me if you would like to continue the dialog.

    Sincerely,
    Rebecca Hamilton
    W.S. Badger Company

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