Tunnel vision

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.

Tunnel vision 750 x 500If 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.

By |2018-04-24T20:26:16+00:00February 23rd, 2010|Legislation|40 Comments

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  1. Kayla Fioravanti February 23, 2010 at 7:09 pm

    Thanks for a very clear and easy to follow explaination of how this bill and ones like it will effect the natural industry.

  2. Donna Maria Coles Johnson February 23, 2010 at 7:31 pm

    Thank you, Robert, for this well reasoned and timely post. Imagine the world without the wonderful essential oils you mention, and other products that companies produce and consumers love. The groups promoting this bill are doing so under the guise of “protecting consumers,” when what they are really doing is simply trying to scare us with a campaign of fear, uncertainty and doubt. They are using donations from organizations like Breast Cancer Fund to, instead of fight cancer, scare everyone into thinking that they are the protectors of the universe. Posts like this, and the actions that will hopefully flow from it, will help all of us wake up and understand that just because a “consumer group” says it, does not make it so. And I love your point about living in a bubble.

  3. Lisa M. Rodgers February 23, 2010 at 7:43 pm

    What a fantastic post! No doubt, if this bill passes, we will see more of the same. I will be passing this on to my blog readers and customers. Consumers deserve reliable information instead of the fear mongering the EWG/Campaign for Safe Cosmetics has been passing off as fact.

  4. Ann Wooledge February 23, 2010 at 8:27 pm

    It continues to amaze me and cause me to stop and ponder – where are these people getting their information? Who is making these decisions – are they actually discussing any of these issues with people who know anything about cosmetics, essential oils, or any of the other areas under debate? It reminds me of a lot of hospital administrative decisions that were made concerning nurses such as building a new unit, wing or hospital – didn’t ask the nurses what they thought would work best – or just even better. And on occasion, they would invite a nurse or two to the “committee meeting” and promptly ignore their suggestions. No, they just discussed it among themselves with no real working basis for their decisions. This is being repeated over and over again in our nation in other arenas. Skin Deep is in particular extremely aggressive and political. What is their real agenda I keep asking myself? Can’t be because they really believe all of this bunk they are putting out. My only conclusion can be as Donna Maria mentioned, they are taking donations from groups they have convinced will be helped by this media blitz of misinformation.

  5. Marge Clark February 24, 2010 at 6:17 am

    Thank you, Robert, for this clear and cogent article. Thinking that the day may come that we have to put a notice on our website…”Colorado residents, keep out, we can’t ship our products to you.” Rose Bliss Bath… sorry, no, you can’t use Rose Oil.

  6. Kristin Fraser Cotte February 24, 2010 at 6:38 am

    Terrific post. What CO is proposing is not the solution. We want to keep our customers and ourselves safe, but presenting the whole story is key. It’s very troubling to see the EWG / Campaign for Safe Cosmetics / Skin Deep influencing legislation based on incomplete science. Their basis is good; their science is lacking. Ironically, it may end up hurting us all more than protecting us and bringing safer personal care to the marketplace… that is what they stand for, right?

  7. DF February 24, 2010 at 6:48 am

    Hi Robert, Once again your calm, educated head prevails on a thorny issue. Let’s hope enough people get this message before it becomes too late.


  8. robert February 24, 2010 at 7:21 am

    “We are opposing the bill,” vice president for public affairs and communication at the Personal Care Products Council Lisa Powers told CosmeticsDesign.com USA.

    “They are proposing to ban products that are legally marketed under the FDA’s regulation. It is grossly overreaching and lacks any scientific basis,” she added.

    If passed, citizens, rather than the state, would be the enforcers of the act. This is not the traditional way of enforcing such a bill, commented Mike Thompson, senior vice president at the Personal Care Products Council.

    “The way the bill has been presented allows the public and their attorneys to enforce it. Essentially, it allows the public to sue companies directly,” he said.


  9. Mindy Green February 24, 2010 at 8:24 am

    Great comments, Robert. The proposed bill in Colorado sounds like California’s Prop 65 all over again; the only winners are unscrupulous attorneys. It seems the best defense is vigilance and sane public education in the face of seemingly reasonable voices in the name of “consumer safety”.

  10. Barbara Lucks February 24, 2010 at 9:35 am

    Thanks, Robert, for a reasonable and understandable perspective on this bill.

    The state of Colorado has a habit of passing bills that have no established enforcement mechanisms, but set up the platform for civil lawsuits. This practice is causing all manner of problems in homeowners association governance.

    If a matter is judged injurious to public health and welfare, it does not make sense that the state would not enforce it. The fact that someone who feels they have been injured must bear the personal expense of hiring an attorney is a disconnect with the Colorado’s stated intent to protect consumers. Who is driving this?

    I agree with Mindy Green that sane public education is important. Virtually anything can be injurious if abused or used to excess.

  11. Valerie R. February 24, 2010 at 10:08 am

    Thank you so much for this reasoned and timely post. The EWG managed to get similar legislation passed in California. While California already has a reputation as being ‘unfriendly’ to businesses, this legislation just made it that much worse. I do hope that Colorado is spared from this.

  12. Marcia Elston February 24, 2010 at 12:10 pm

    Donna Maria, Kayla, and now Robert have given us well reasoned challenges to express to lawmakers. Add the position of Personal Care Products Council and we now have foundational fact to effectively turn the tide. Thank you, Robert.

  13. Shellie Enteen February 24, 2010 at 1:17 pm

    As many others have said, a big Thank You for this article. I have bookmarked this link for my current Professional Level Aromatherapy class. We have just been discussing this situation!
    With best regards.

  14. JoAnne Bassett February 24, 2010 at 5:25 pm

    Thank you Robert and all for getting the word out. I have been watching the vitamin, herb, and essential oil scares for years. I do not like what I see coming down the road. WE have got to stop this before it spreads…

  15. Joan Morais February 24, 2010 at 7:28 pm

    Great informative article.

  16. Michelle Gilbert February 24, 2010 at 8:52 pm

    Thank you for this brilliant post. I’ve linked to your article and posted a quote from it on my own blog for my own readers and customers. I’m so tired of scare after scare, each worse than the next. All, as Mindy says above, for “consumer safety”.

  17. Sonsa Rae February 24, 2010 at 10:17 pm

    What can we do on a personal and/or group level to keep this from spreading any further and to stop Colorado’s proposed bill dead in its tracks? What voice do we have as an industry? There are thousands of us in the United States who use essential oils for numerous purposes as an Aromatherapist, Aesthetician, or Manufacturer of personal care products and sometimes all three. We thought the EWG was watching our back and, come to find out, just the opposite is true. What organization IS, that has enough muscle to fight something like this? I would like to know!

  18. robert February 24, 2010 at 11:58 pm

    Thank you all for your supportive comments. “Tunnel vision” is of course not peculiar to EWG, and is very common in the attitudes of regulatory agencies. “Zero tolerance” is much less common, especially when a substance is widespread in foods and edible plants. Like many others, I used to be an admirer of EWG, and my views have completely turned around over the last 1-2 years. I’m certain that no-one in EWG knew that one of the many, many substances they are targeting is found in fruits and vegetables. I’m sure because it is symptomatic of their sweeping, scaremongering politics, that don’t leave room for nuanced thought. As for Colorado, I can assure you that there are plans in the making to address this – I believe their is a meeting next week. The “base camp” is peopled by all the people whose blogs you have been reading. As for dealing with the long-term problem of similar issues always needing attention somewhere, the simple fact is that legal people are needed, and money is needed, and there are currently no essential oil-based organizations that could make enough consistent noise. But, the AIA is talking to the AHPA about collaborating,as the AHPA have muscle. I am going to an AHPA meeting at Expo West on March 12th.

  19. Sheryl Karas February 25, 2010 at 1:57 am

    Well said! Thanks for the balance you add to this issue.

  20. soap bartender February 25, 2010 at 5:28 am

    Great post. I’m all for safer cosmetics, and I too used to be a fan of EWG, but they’re taking this way too far. Where’s the common sense???

  21. Patricia February 25, 2010 at 8:09 am

    I’m from Colorado and I am wondering if our state legislatures don’t have anything better to do? I am a massage therapist and aromatherapist and have seen only good from my pure oils. Thanks for letting me know what it going on. And, thanks to those people who can get to that meeting and straighten it out!

  22. Melissa February 25, 2010 at 9:37 am

    Thanks for this and to all the others who have written about this legislation. Very informative and thought provoking.

  23. William R McGilvray February 25, 2010 at 10:14 am

    Thanks, Robert, for shining the light yet again. Mindy, I’d put a slightly different slant on it: this is in the GUISE of consumer safety. Ultimately, consumers are the biggest losers, as their choices and rights are eroded in the name of protection. Protection from what is the real question.

    Wonder who drives EWG? Wonder no more. Just google EWG + Codex. “But,” I hear you cry, “the discussion there is about Electronic Working Group, not Environmental Working Group.” EWG. Think about it.

    I have been speaking out against the inexorable march of Codex Alimentarius for over 15 years. To those of us in the essential oils, natural extracts, and cosmetic materials world the nub of the problem is the global push for all synthetic and natural chemicals in whatever form to be moved from the (largely grandfathered) ‘Safe until proven Unsafe’ list to an ‘Unsafe until proven Safe’ list. In the EU countries it is the objective of REACH legislation. In other countries the name may be different, but the objective is the same. The USA is the major stand-out in the Western world, and continuing non-compliance will increasingly impact on the USA’s international trading relationships. So, get ready for the change.

    While at times inconvenient, the impact on major global suppliers of raw materials is in contrast to the impact on small-to-medium sized companies. Compliance with safety legislation by major companies is just a part of the cost of doing business, and all companies within the EU are now learning how to live with the regulatory requirements.

    However, the ability of each of the small companies and individuals represented in this and similar forums to conduct major safety trials for each of the materials that may be used in the context of a formulated product is basically non-existent. That is not to excuse anyone from taking every possible step to ensure product safety, and accuracy of ingredient and product information.

    What to do? Here is the slogan that I came up with in my days as president of the Australian Tea Tree Industry Association: “United we bargain, divided we beg.” I commend it to all as the first defense in this present focused assault, with more to come.

  24. Natural Grocers by Vitamin Cottage February 25, 2010 at 3:46 pm

    We are also strongly opposing this bill. The Judiciary Committee of the Colorado Legislature will either move this bill forward or “postpone it indefinitely” at its committee meeting on Monday, March 1st at 1:30 pm in the state house. We were lobbying the committee members this afternoon, with some surprising bedfellows: Amway, Target, Walmart, MaryKaye, and Merle Norman, among others. (Geez they all looked and smelled great!;)

    The Colorado Woman’s Lobby is backing this bill, and using the signors of the Compact of the Campaign for Safe Cosmetics as “proof” that small body care and cosmetics businesses support the bill itself. Anyone reading here who has signed the Compact may want to reconsider, or at least send a note to the bill’s sponsor saying you do not support the bill in its current form.

    Feel free to e-mail us at alewis at vitamincottage.com

  25. Mill Creek Botanicals February 25, 2010 at 5:34 pm

    Even though we are not a resident of CO we sell our products in this beautiful state and do not back this bill either. This is another bill like S 3002 proposed by McCain (which will devastate the supplement industry) that is a extension of big government telling us how we have to live and what we can and can not do. We are the land of the free, home of the brave… not the land of massive regulation and home of the fearful. Bills like these need to be stopped in their tracks and government officials backing bills like these need to be voted out by the people which will send a message that we will not tollerate such bills. It is important to step back take a deep breath and ask… who is this bill really benefiting?

  26. Gina Rafkind February 26, 2010 at 1:58 pm

    Thank you Robert for posting this easily understandable article. I would so miss all those essential oils that you mentioned above and how sad to see these gifts of nature be torn away from us. I’m going to pass this along to my blog readers as well so they too will be informed of this legislation. I’d love to hear how your meeting goes on March 12th.

    Are people that power-hungry – this always amazes me.

  27. Tanya LaMothe February 27, 2010 at 8:43 am

    I have been reading about much of this from Tony Burfield (Cropwatch) over the years. Regulations for the common folk; to protect us? Thank you for your information and the “heads up”; well written. Articles like this from people like you are so helpful to those of us out here in the trenches, sifting through much of the info that is coming in on the wire. We can trust what you write. You are genuine & there are many of us out here blending that are as well, with no agenda other than helping people with skin conditions and emotional issues that essential oils so beautifully & positively address. I cannot imagine operating my skin care, energy healing business without these oils. Informing our community members is key & that is what we will do with articles such as these. Your informations is key in getting the public informed; again, thank you for sifting through all of the legal language. Keep it coming 🙂

  28. Lucy Miller February 27, 2010 at 8:44 am

    Well said Robert!
    The “Tunnel Vision” actually expands beyond these things that you mentioned here in your blog statement. I am a ARNP, nurse anesthetist and I can tell you that I am way more concerned by the daily exposure that the normal person encounters in a hospital/operating room then many essential oils. This act seems somehow misguided and possibly the aim is not really protecting the consumer, but rather limiting access to the handmade movement?
    Thanks Robert.

  29. Marlene Mitchell February 27, 2010 at 10:58 am

    “Dear” Robert: There are wonderful people in Colorado who are aromatherapists who I truly love and admire. I would not want them to suffer. I want the best for them as well as all aromatherapists. We need our therapeutic healing oils. If this bill passes, this could be the beginning of something horendous. Being an aromatherapist here in Canada, I certainly would not want this to happen to our country as well. If this bill passes in beautiful USA, this could also have a ripple affect in Canada as well as the rest our beautiful world. I wish many blessings on March 14 and hope that this bill does not pass.
    Many aromatic Blessings.

  30. Laurie Brekke March 1, 2010 at 9:18 am

    This is truly interesting and thank you for your post! I am a “fan” of EWG on Facebook so I see their posts. I was so upset that they would be part of such a terrible bill, so I went to their main page and put up a comment about this with a link to your blog and this was their response: “Laurie, We’re not working on any legislation in Colorado. It must be another group. Lisa”. I thought that was interesting…So maybe they dropped support of the bill? I know they are working to pass one in NJ….

    Thanks for your work! Laurie

    • robert March 1, 2010 at 11:12 am

      Laurie, if you go to http://coloradowomenslobby.org/news-and-resources-about-safe-cosmetics you will see that the Women’s Lobby of Colorado is actively supporting the bill. The WLC is an “endorsing organization” of the Campaign for Safe Cosmetics, and the CFSC, Skin Deep and the EWG are all family. If you are familiar with EWG you will know that.

      Are the EWG in favor of the bill, not in favor of the bill, or do they know nothing about it?

    • robert March 1, 2010 at 11:19 am

      I guess they needed a Colorado-based organization to take action in Colorado.

  31. Laurie Brekke March 1, 2010 at 12:01 pm

    Hi Robert – you raise an excellent point! Since I know very little about the bill and don’t have any Senators or local Reps that I can call (as I don’t live in CO), I would encourage state residents & heavyweights in the industry (such as yourself, DoTerra or YL) to get involved. I don’t know if you are a “fan” of EWG on Facebook, but if so, just go to their wall and you’ll see my post and the response – you can post comments as well and perhaps they’ll respond more clearly 🙂

    Again, thanks for what you’re doing. I’m going to take a strong look at the bill they’re proposing in NJ and contact folks there…


  32. Cee Moorhead March 1, 2010 at 1:29 pm

    Coloradoan here! Unfortunately, we are not very well organized, but are feeling the pinch to do something about this. Due to the short notice of this pending legislation, I myself am just now getting up to speed. Hopefully, we will be better prepared if it has a second public hearing.

    According to the local News last night, two states already have a similar bill in place, with nine more states soon to follow suit. My first thought this morning is that we need to start a writing campaign to get Ambassador Carol Moseley Brown on Oprah to discuss this issue. A ‘public forum’ of that magnitude may be just the thing to stop it dead in its tracks. Ambassador Braun is a speaker at the HCSG Conference in Denver this year. You can see from her bio here that she is very well qualified to address this issue:


    Cee aka Zany in CO

  33. Denise - MCS Patient March 11, 2010 at 6:47 pm

    With respect for Ms. Mitchell’s beliefs, there is no such thing as a harmless essential oil. I used to think oils provided a sensual respite from the harshness of daily life. That was until my husband and I were exposed to highly concentrated amounts of aromatherapy type oils including oil of oregano, clove oil, cinnamon oil, lemon oil, basil oil to name a few, when they and others were diffused in our home to kill mold. Each of the oils included in the product used in our home, was analyzed and documented in MSDS documents which are required by OSHA.

    Per the related MSDS sheets, many of the oils posed extreme health hazards when applied in poorly ventilated areas. The oil product was applied anyway. My husband and I have become chemically sensitive as the result of the exposure. Our illness is called Multiple Chemical Sensitivity (MCS). To most people MCS means nothing. To the millions of us that know all too well what it is, know that life as one knows it ends once sensitivity occurs. Finding safe housing can be nearly impossible. Finding a car that is free of harmful chemicals (new car smell includes a large element of formaldehyde) is daunting. Forget about trying to find a safe rental car. Safety in each of these contexts means freedom from becoming violently ill in whatever environment it describes.

    While Lucy Miller may not agree with my comments to this point, she is spot on in regard to the dangers posed by the sort of substances and chemicals one encounters in an operating room.

    The Colorado Law does not go anyway near far enough. What about pesticides, herbicides and the fertilizers that we and our small children come in contact with everyday through our food and environment?

    Promoting an environment which is safe from chemical threats is not to be left to dilatants seeking a cause through which to “feel good”. A safe environment is a must have, worthy of being fought for.

  34. Laraine Pounds March 13, 2010 at 6:26 am

    I have been in e-mail contact with a representative of the CO legislature who sponsored the bill. It did not pass this initial vote and is being re-written and will be re-introduced later for another vote. They are firm in their resolve to pass some version of this bill.

  35. Pepper Pascal March 15, 2010 at 7:53 pm

    Thank you. This makes a lot of sense.

  36. Ambrosia March 24, 2010 at 4:29 pm

    Strikes me that your article provides one of the main reasons to go back to useing natural ingredients in perfume: The concept that plants have combinations of ingredients in them that make them work beneficially together…whereas isolated chemicals on their own can be harmful!

    Quite apart from them smelling so much better and being so much more delightfully complex of course…..


  37. Erin August 4, 2010 at 4:48 pm

    Thank you so much for your article! I just found it today- researching info for my article about HR 5786 The Safe Cosmetics Act 2010. What an incredible resource!!
    I linked to you in mine-
    Are you taking an active role in the current fight again this latest attack on our liberty and sensibilities? I sure hope so. We can use your wisdom and knowledge!
    owner, The Natural Bar Soap Company

  38. […] Ingredient tunnel vision is seriously bad for your health. It will turn you into an obsessive, paranoid, vicious, spitting fireball of righteous indignation. You will write searing blog posts, develop gastritis or worse, lose sleep, and die young. And for what? Essential oils and their constituent chemicals are very frequent targets. Because essential oils contain chemicals, and because almost all chemicals are, to some people, toxic by definition, many bloggers in the green movement have become anti-fragrance and anti-essential oils. For a while I though that, when they realize that linalool is found in lavender oil, and that limonene is in lemon oil, they will relent. I was wrong. Obsession is, in fact, relent-less. It allows no release, no vacation, no light side. It is all-consuming! […]

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