The cosmetic industry’s safety panel (the Cosmetic Ingredient Review, or CIR) has screened for safety only 11 percent of the 10,500 ingredients that the FDA has documented in personal care products. EWG’s analysis of product labels shows that ingredients not yet screened are found in more than 99 percent of products on the market.

The products shown below are the few comprising the the less than one percent of products for which all ingredients have been screened for safety by the CIR, drawn from EWG’s assessment of labels from14,835 products. Some of these products also contain ingredients that are innocuous (e.g., water and oatmeal); fragrances that have been reviewed for safety by the fragrance industry (International Fragrance Association); or color additives approved by the Food & Drug Administration.

CTFA staff scientist and frequent spokesman Gerald McEwen is the primary advisor of the industry-funded panel on which the FDA relies for decisions relating to personal care product safety. A new EWG analysis has discovered that he frequently cites incorrect information about product ingredient labels.

October 12, 2005

Ms. Pamela G. Bailey
The Cosmetic, Toiletry, and Fragrance Association
1101 17th Street, NW

Suite 300
Washington, DC 20036-4702

Dear Ms. Bailey:

As you might have heard by now, Environmental Working Group (EWG) is preparing to release a significantly expanded version of our consumer guide “Skin Deep,” enabling the public to learn more about the ingredients in their personal care products and whether they have been assessed for safety. We will feature brand-by-brand rankings.

Consumers should not have to depend on a small watchdog organization such as mine to provide them with a user-friendly service that catalogues and compares personal care product ingredient lists and matches them with government data on ingredient hazards. The U.S. Food and Drug Administration (FDA) should do this or at least require your industry to do so.

Our expanded, year-long review of online ingredient lists has led us to a number of conclusions.

First, reliable government standards and procedures are not in place to assess the safety of ingredients your industry uses. Federal health officials instead rely heavily on the guidance from the Cosmetics Ingredient Review panel, which is funded and controlled by your organization and advised by your organization’s vice president of science and frequent spokesman, Gerald McEwen. The FDA has no national standard for what is a safe ingredient, and they just told us they wouldn’t set one.

Second, it’s clear that your industry has so far decided to fight any change in this self-regulatory status quo. As you know, over the concerted opposition of your organization and some of its member companies, California Governor Arnold Schwarzenegger signed into law last week a measure that will require your members to disclose which of their products contain chemicals linked to cancer, reproductive harm or developmental toxicity. This new law, the California Safe Cosmetics Act of 2005 (SB 484), creates one opening for a serious discussion about options for improving cosmetics safety. We’d like to have that discussion with you at a meeting at your earliest convenience.

Finally, while our primary disagreements with your organization center around safety standards and assessments for personal care products, we’ve been struck by even more basic problems that seem to afflict your industry: counting and spelling.

On a number of occasions Mr. McEwen has claimed that EWG overestimates the number of ingredients used by your industry. He has said that the total number of ingredients used is “probably around 2,000,” (Washington Times, 8/14/04) but he has also said the number is “really less than 4,000” (Women’s eNews, 2/28/05).

Our forthcoming assessment of the ingredient lists posted online by your industry for 14,200 products yields a total of 13,986 ingredient names. When we sorted for the misspellings, synonyms and improper names carried by your member companies’ product labels as posted online, we totaled more than 6,800 unique ingredients. Roughly 50 percent of all ingredient names were misspelled or did not conform with preferred ingredient names in your industry’s own International Cosmetic Ingredient Dictionary and Handbook, 10th edition, 2004.

We are confident that the discussion that ensues next week, when we release the next edition of “Skin Deep,” will quickly move beyond your industry’s counting and spelling problems and focus instead on ways to improve public policy as it pertains to personal care products.

Thank you in advance for considering a meeting with us.


Kenneth A. Cook