Scratching Below the Surface :: Dene Godfrey Article Regarding Skin Deep

I recently 'met' Dene Godfrey, President of the Society of Cosmetic Scientists on LinkedIn at a group called Cosmetics and Beauty Network.  There have been many discussions regarding the Skin Deep on the forum, including a large one that got deleted recently by the person who started the conversation stream. 

    

Yesterday a new conversation was started regarding the need to share information regarding the fact that Skin Deep and the Environmental Working Group are not using science to back up their claims.  This guest blog post is a result of that conversation. 

Scratching Below the Surface, by Dene C Godfrey

From the EWG web site:

“The mission of the Environmental Working Group (EWG) is to use the power of public information to protect public health and the environment. EWG is a 501(c)(3) non-profit organization, founded in 1993 by Ken Cook and Richard Wiles.

In 2002, we founded the EWG Action Fund, a 501(c)(4) organization that advocates on Capitol Hill for health-protective and subsidy-shifting policies.

EWG specializes in providing useful resources (like Skin Deep and the Shoppers' Guide to Pesticides in Produce) to consumers while simultaneously pushing for national policy change.”

From the Skin Deep home page:

“In 2004 we launched Skin Deep, an online safety guide for cosmetics and personal care products. Our aim was to fill in where companies and the government leave off: companies are allowed to use almost any ingredient they wish, and our government doesn't require companies to test products for safety before they're sold. EWG's scientists built Skin Deep to be a one-of-a-kind resource, integrating our in-house collection of personal care product ingredient listings with more than 50 toxicity and regulatory databases.
Now in its fourth year and third major update, our Skin Deep database provides you with easy-to-navigate safety ratings for nearly a quarter of all products on the market — 54,866 products with 8,983 ingredients. At about one million page views per month, Skin Deep is the world's largest and most popular product safety guide"

The aims of both the EWG and their Skin Deep database are laudable – who could disagree that cosmetics should be safe? I doubt that any responsible manufacturer would ever knowingly put their customers at risk by placing products on the market that are not safe for their intended use. EWG insist that there is virtually no regulation of cosmetics in the USA, but this is not the case. The FDA requires that manufacturers do not place products on the market that are unsafe to human health and, whilst there may not be the same level of regulation as in , for example, the European Union, it is not true to say that cosmetics are unregulated. The EWG/Skin Deep promote themselves as the champions of safety (in cosmetics, for the purposes of this paper), but this is not actually what they achieve.

The database uses an impressive array of numbers (of products and data sources) and an impressive-looking amount of detailed explanation as to how their system of classification works, including some complicated-looking formulae. For the fine detail, click here.

The mainstays of this system are the following:

“Hazard (concern) rating. We developed a hazard rating that represents a synthesis of known and suspected hazards associated with ingredients and products. Hazard ratings within Skin Deep are shown as low, moderate, or higher concern categories, with numeric rankings spanning those categories that range from 0 (low concern) to 10 (higher concern).

Data gap rating. We developed a data gap rating within Skin Deep, primarily to describe the extent to which low hazard scores associated with some ingredients or products are based on definitive data demonstrating safety or, at the other extreme, on a near absence of data either demonstrating or disproving hazard. Data gap ratings are represented within Skin Deep by a numeric percentage ranging from 100% (complete absence of safety data) to 0% (comprehensive safety data). “
Already, several concerns creep in:

1. It is not possible (at least, not without a high degree of subjectivity) to assign a numerical value to a hazard. A hazard is a hazard. It is not logical to compare something that is highly corrosive to something that is toxic by ingestion – it is the same as comparing apples with pears.
2. On whose authority is the “suspected” hazard determined. Again, this is highly subjective. If there are no data, how is it possible to suspect a hazard?
3. How is it possible to rate a data gap so empirically? The impact of any data gap is wholly dependent upon the nature of the data that are missing.
4. They make the statement – “A hazard rating of "low concern" (shown as a green circle in Skin Deep) might be rated in that category because of definitive data proving its safety, or because of a near absence of any safety studies that would illuminate hazards.” How can absence (or near absence) of data ever be shown to illuminate hazards?
5. They claim to offer “safety ratings” – they do not – they only offer hazard ratings.

On looking more closely into the database and, specifically, at various products and their hazard scores, there are many obvious issues. There is a group of closely-related compounds that are assigned hazard scores entirely the opposite of their true relative hazardous nature. There are examples of the same chemical being listed under two different names with different hazard scores.

One word that has arisen many times in this discussion, and on the Skin Deep database is “hazard”, and therein lies the basic issue with Skin Deep. It is entirely based on hazard, with no attempt whatsoever to evaluate risk. It is not possible to evaluate safety of the basis of hazard alone. If a chemical was in existance that required only a single molecule to kill a human, that would be described as extremely hazardous. However, if only one molecule of that chemical actually existed, then the chance of human exposure is insignificant, and the risk to human health is also insignificant. I use an extreme example to better explain the relationship between hazard and risk, which may be summarised as follows:

RISK = HAZARD x EXPOSURE

Because the database only highlights the hazard of the ingredient, there is no possible way the consumer can know the actual risk involved in its presence in a cosmetic product. In our daily lives we constantly assess risk, albeit mostly subconciously. If we avoided every hazard without ever considering risk, we would never cross a road, and we would never stay in our homes (as the majority of accidents occur in the home, so there is a definite hazard associated with being at home). As it is nonsense to live our lives with assessing risk, it is equally nonsense to avoid any particular chemical without assessing the risk. It may even be the case that high exposure to a product classified by Skin Deep as zero is less safe than low exposure to a product classified as 10 on this database. Therefore, the database offers no useful information on the safety of cosmetic products, and is misleading to consumers.

Regarding hazard, it is possible, given the correct dose and route of administration to establish a hazard for EVERY chemical in existance, be it natural or synthetic.  If anyone decided to carry out an inhalation study using any chemical either in vapour, mist or powder form, it would result in death. The only substance that would not have this effect is air (although the individual components of air would cause death), and even inhalation of too much air too quickly can result in dizziness and unconciousness. Therefore every chemical is hazardous.

For a little light relief, I suggest that you investigate the extreme hazards posed by dihydrogen monoxide by clicking here.

The treatement of data gaps is of particular concern. This is, again, highly subjective. Some ingredients with 100% data gaps are assigned zero, but others are assigned 3, or higher. How is it possible to assign a hazard rating when there are no data? It is entirely possible that many companies, appreciative of the marketing benefits of being able to claim a zero hazard rating on Skin Deep, are designing products specifically using ingredients with a zero hazard rating. There is certainly at least one company using this tactic. This means that products are being manufactured using ingredients with no safety data! Given that the EWG make great play of their claim that the USA do not regulate cosmetics, is it wise of them to encourage this practise, albeit tacitly?

The use of hazard classification alone enables Skin Deep to provoke concern amongst consumers.  Without this concern, they would get little in the way of donations.

Another quote from the EWG site:

"Under federal law, companies can put virtually anything they wish into personal care products, and many of them do. Mercury, lead, and placenta extract — all of these and many other hazardous materials are in products that millions of Americans, including children, use every day," said Jane Houlihan, Vice President of Research at EWG.

This strongly implies that mercury and lead are deliberately added into cosmetic products which (apart from a few mercury-based products used as skin-whiteners) is simply not true. Again, the comment focusses on hazard only. I am not going to comment on placenta extract as I don't know why anyone would want to use that in the first place, and I am not sure of the potential risks involved in its use., but this is more evidence of manipulation of information in order to scare consumers in a misleading manner.

At the 2010 Expo West (which, for the benefit of those not based in the US, is the largest natural products show in the country) the Environmental Working Group's Skin Deep Safety Review Group's booth reportedly had a banner which read "If you can't pronounce it, it can't be safe"!

Following this logic it must be the case that if you CAN pronounce it, it must be safe. Try pronouncing “hydrogen cyanide”.
 
Two final quotes from the Skin Deep web site:

“This scoring system does not account for individual sensitivities or differences between the severities of different health endpoints within a particular category.”

And at the head of every product’s hazard rating:

“Given the incomplete information made available by companies and the government, EWG provides additional information on personal care product ingredients from the published scientific literature. The chart below indicates that research studies have found that exposure to one or more ingredients in this product -- not the product itself -- caused the indicated health effect(s) in the studies reviewed by Skin Deep researchers. Actual health risks, if any, will vary based on the level of exposure to the ingredient and individual susceptibility -- information not available in Skin Deep.” (My bold type; not Skin Deep’s)

Does the average consumer looking at the database even read these disclaimers, never mind understand that they are saying that their ratings refer to the individual ingredients and that information on the ACTUAL health risks of the product in question is not available in Skin Deep?

In summary, the Skin Deep database does not offer any insight into the true safety in use of any cosmetic product. Indeed, by encouraging the use of ingredients with no supporting toxicity data, they are risking the health of the very consumers they pupport to be seeking to protect. This database should be radically amended (and corrected) to better reflect it’s true worth, or closed down.

Dene Godfrey, 20 April 2010 gives permission for this article to be reprinted with NO CHANGES. 

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[SL Meyer]

"...the Environmental Working Group's Skin Deep Safety Review Group's booth reportedly had a banner which read "If you can't pronounce it, it can't be safe"!"

What a silly statement! I guess the EWG doesn't think much of the INCI then, considering that 6 out of 10 people can't pronounce most latin words as it's not commonly taught anywhere anymore. Granted, most US labels have the english translations in parentheses, but at least once a day I have to explain to customers that cosmetics DO have regulations and that the labeling is the way it is so that most everyone in the can get the exact ingredient list translation and not the "common" name which can actually vary from region to region, even more country to country. Not to mention how some plants have cousins that can go by the same "common" name. Lavender is one, I can think of 4 kinds off the top of my head. Chamomile is another and is my classic example. How many average customers/people know there are 3 chamomiles? I do, you do. That's our business, we HAVE to know. But most people cannot pronounce them. So should they not use them because they can't pronounce them?

I just shake my head at the EWG and wonder what they are really up too and what their true agenda is. It's a lot of smoke and mirrors with them.

[Donna Maria Coles Johnson]

This is a wonderful post. Thanks Dene for allowing Kayla to share it, and Kayla for placing it here. This is a clear example of how generalities can be used to create false impressions and conclusions that lead to poor public policy - which always leads to poor laws. If the Environmental Working Group really had consumers' interests at heart, it would not use its resources to engage in broad and sweeping condemnations. It wold instead do the research and expose real truths, not half-truths that make good media sound bites.

It is my hope that all affected parties can work together to accomplish good that really serves consumers. That has to start with science, which has to lead to objective and credible people interpreting the data and sharing it with laypersons in ways that inform and help them, not scare and whip them into a frenzy of activity signifying nothing.

Thanks again Dene and Kayla!

[Anne-Marie]

This paragraph, the closing one, says it all for me. I read the entire thing but for anyone that doesn't want to read the entire thing, if you read anything, just read this one paragraph:

the Skin Deep database does not offer any insight into the true safety in use of any cosmetic product. Indeed, by encouraging the use of ingredients with no supporting toxicity data, they are risking the health of the very consumers they pupport to be seeking to protect. This database should be radically amended (and corrected) to better reflect it’s true worth, or closed down.

Thank you Kayla for posting this.