Why aren't all products safe?
Teen Girls' Body Burden of Hormone-Altering Cosmetics Chemicals: Why aren't all products safe?
Adolescence is a time of experimentation and the first steps toward independence. Girls entering adolescence have often begun a lifelong exploration of their own individual styles, which may be expressed in part through the beauty and body care products they use. Like most Americans, teens assume that personal care products readily available on store shelves do not contain ingredients or impurities known or suspected of causing lasting damage to human health.
In fact, the Food and Drug Administration (FDA) has no authority to require testing of personal care product ingredients for safety before they are sold. Instead, FDA states that the manufacturers of these products, with few exceptions, "may use essentially any raw material as a cosmetic ingredient and market the product without an approval from FDA" (FDA 1995). While the required ingredient list on body care products provides consumers, including teens, with some information, this list does not document the presence of impurities – contaminants formed when a raw material is manufactured, or when it breaks down within a product – many of which are commonly found in cosmetics. Worse, FDA does not have the power to require the recall of a harmful product – recalls are voluntary company actions, and the mere act of FDA suggesting a recall requires that the Agency have firm evidence of potential human harm.
In place of government authority to ensure safety, the personal care products industry polices itself through an industry panel called the Cosmetic Ingredient Review (CIR). This industry-funded panel of scientists has reviewed just 11% of all ingredients in cosmetics, including many no longer in regular use. An EWG investigation found that the panel chooses criteria regarding sensitivity and irritation for 80% of its safety recommendations, ignoring more serious health concerns such as cancer, birth defects, and hormone disruption, and as a result finds more than 99% of ingredients reviewed safe as used. What's more, companies are not bound by the panel's restrictions or recommendations – compliance is entirely voluntary.
As it stands, it's up to individual cosmetic companies to make decisions about safety – for adults and teens alike. Some companies make body care products safe enough to eat; others make products using ingredients with documented links to birth defects in humans, or ingredients laced with cancer-causing impurities.
Companies are also free to represent their products in any way they choose - marketing claims for body care products are entirely unregulated. FDA tried establishing official definitions for terms like "natural" and "hypoallergenic," but these protections were overturned in court. As a result, manufacturers can use marketing claims "to mean anything or nothing at all" (FDA 2000). According to FDA, "Image is what the cosmetics industry sells through its products, and it's up to the consumer to believe the claims or not" (FDA 2000). While FDA has taken pains to research and account for the still-maturing decision-making abilities of teens using over-the-counter medications (FDA 2007b), they have made no attempt to protect teens from the deceptive marketing practices used in the cosmetics industry.
Body care products provide an appalling example of the inadequacy of current chemical regulations in the U.S. The Federal Food, Drug, and Cosmetic Act, the law governing cosmetics safety, does not require companies to test products for safety before they are sold. The Toxic Substances Control Act, the law that regulates all industrial chemicals in the United States, was created over 3 decades ago, and assumes chemicals in everyday products are innocent until proven guilty. The products we and our children use each day can contain thousands of ingredients that have never been tested for safety.
We cannot continue to allow a self-regulating industry to make decisions about the health of young women and men throughout America. Health protective reform of chemical standards must include:
- Premarket testing of products and their ingredients for safety.
- Protective purity standards for ingredients.
- Attention to the effects of mixtures of chemicals on human health.
- Safety standards that acknowledge critical developmental “windows of vulnerability” to chemical exposures, including the period of adolescence.