This article originally appeared in the November 1991 FDA
Consumer. The version below is from a reprint of the original
article and contains revisions made in May 1995. More
information about cosmetics is available from FDA's Center for Food
Safety and Applied Nutrition.
FDA AUTHORITY
OVER COSMETICS
FDA is only able to regulate cosmetics after products are
released to the marketplace. Neither cosmetic products nor cosmetic
ingredients are reviewed or approved by FDA before they are sold to the
public.
FDA cannot require companies to do safety testing of their
cosmetic products before marketing. If, however, the safety of a cosmetic
product has not been substantiated, the product's label must read
"WARNING: The safety of this product has not been
determined."
Fragrance Free?
Don't be fooled!!!
Products so labeled may still contain small
amounts of fragrances
to mask the fatty odor of soap or other unpleasant odors ..."
Chemical Ingredients found in cosmetics- See below
Cosmetic
Ingredients:
Understanding the Puffery
DECODING
THE COSMETIC LABEL
HYPOALLERGENIC
COSMETICS
Summary
of Color Additives Listed for Use in the United States in Foods, Drugs,
Cosmetics, and Medical Devices
Alcohol
Free..Really?
Cruelty Free or
NOT?
The
Truth About "No Animal Testing
Lot's
more information on Cosmetics at the FDA's Website
Things you do and wear can make others
sick...take a look.
-
tobacco or smoke
-
perfume, cologne or after-shave
-
hairspray, mousse, scented shampoo or hair conditioner
-
scented deodorant, lotion, lipstick
-
any scented personal care or cosmetic product,
including herbal essence, essential or natural oils, medicinal or
herbal lotions or oils, flower remedies, etc.
-
pesticide or herbicide
-
recently dry cleaned clothing
-
scented laundry detergents such as Tide
-
fabric softener or dryer paper (even those labeled
unscented or fragrance-free*)
-
shoe polish
-
chewing gum
-
odor of alcoholic beverages
Check
out Phoney Do Gooders ...what an eye opener!!
To my conservationist friends. The
Sierra Club has acknowledged that"
The excessive use of fragrance products in both personal
care and in cleaning and maintenance operations poses a risk to public
health and an unpleasant nuisance"
In 1986, the National Academy of Sciences (NAS) targeted fragrances as
one of the six categories of chemicals that should be given high priority
for neurotoxicity testing, with the others including insecticides, heavy
metals, solvents, food additives and certain air pollutants;
The NAS also reports that 95 percent of chemicals used in fragrances
are synthetic compounds derived from petroleum, such as benzene
derivatives, aldehydes and other known toxics and sensitizers capable of
causing cancer, birth defects, central nervous system disorders and
allergic reactions;
It has been reported by the U.S. Environmental Protection Agency (EPA)
that toxic chemicals are present in fragrance pro- ducts;
There has been a significant increase in the number of people with
sensitivity to these fragrances, which are advertised as benign products,
and these acute sensitivities can lead to debilitating and disabling
conditions in men, women and children of all ages;
Read
more now!
Envorinmental Health Network
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by Dori Stehlin
The European cosmetic known as ceruse was used faithfully--and fatally,
because it was mainly white lead--by wealthy women from the second century
until well into the 19th century to make their faces look fashionably
pale.
Nothing on the market today approaches ceruse's deadliness. But many
consumers wonder about the eye makeup, lipsticks, foundations, and nail
products that are on the shelves. Are there any risks in using these
cosmetics? Are long lashes, even skin tone, and brightly colored nails
worth any risk at all?
Serious injury from makeup is a "pretty rare event," says
John E. Bailey, Ph.D., director of FDA's Office of Colors and Cosmetics.
"We don't see it happen that often."
Even one of the most serious problems, eye infections from a scratch on
the eyeball with a contaminated mascara wand, has become rare. January
1989 was the last time an infection of this type was reported to FDA.
In 1994, FDA headquarters received approximately 200 reports
of adverse reactions to cosmetics. Skin-care products and makeup
accounted for about 65. Of those, at least 22 concerned products
containing the chemical alpha hydroxy acid (AHA), used in so-called
"skin peelers." Most of the 65 reports were either allergic
reactions or skin irritations. The other complaints were about hair
products, soaps, toothpastes, and mouthwashes.
Although industry probably received about 50 reports for every one made
to FDA, says Bailey, the problems reported to the companies are along the
same lines--allergies and skin irritation.
The agency can't do much about isolated allergic reactions or
irritation problems. It's up to the individual to avoid the product that
caused the reaction and any other products that contain the offending
ingredient. (See "Contact Dermatitis: Solutions to Rash
Mysteries" in the May 1990 FDA Consumer.)
But that doesn't mean reporting the problem isn't important.
"We look for clusters," says Bailey. "If we see we're
getting a number of complaints for the same product, then that is cause
for concern."
Unlike reports of allergic or irritation reactions, even one report of
an acute injury, usually caused by a contaminated product, results in
quick action by the agency. "We'll inspect the establishment, talk to
the consumer, talk to the doctor, collect samples, and analyze them to
determine the extent of contamination," says Bailey.
Moldy Oldies
Contaminated makeup is the result of either inadequate preservatives or
product misuse. But contamination doesn't necessarily translate into
serious injury for the user.
"Cosmetics are not expected to be totally free of microorganisms
when first used or to remain free during consumer use," according to
a 1989 FDA report on contamination of makeup counter samples in department
stores. The report was based on a survey which found that over 5 percent
of samples collected were seriously contaminated with such things as
molds, other fungi, and pathogenic organisms.
Every time you open a bottle of foundation or case of eye shadow,
microorganisms in the air have an opportunity to rush in. But adequately
preserved products can kill off enough of the little bugs to keep the
product safe.
Occasionally, however, a product will be seriously contaminated.
According to FDA data, most cases of contamination are due to
manufacturers using poorly designed, ineffective preservative systems and
not testing the stability of the preservatives during the product's
customary shelf life and under normal use conditions.
Driving and Making Up Don't Mix
Consumers must take an active role in keeping product contamination and
potential infection to a minimum once they take a product home, says
Gerald McEwen, Ph.D., vice president for science for one of the cosmetic
industry's trade associations, The
Cosmetic, Toiletry and Fragrance Association.
"You need [to follow] good personal hygiene--clean hands, clean
face," he says. "And common sense."
One of the riskiest things a woman can do is put on mascara while she's
driving, says McEwen. "You hit a bump and you scratch your
eyeball," he explains. "Once you've scratched your eyeball, you
have all kinds of possibilities of contamination. We're not talking about
disease germs here. We're talking about normal bacteria that are all over
the air. Those get into that kind of a cut, and without proper medical
attention you can go blind."
Testing the Testers
There's something else that is definitely taboo when using
makeup--sharing.
"Never share, not even with your best friend," says Irene
Malbin, CTFA's vice president of public relations. Sharing cosmetics means
sharing germs, and the risk, though small, isn't worth it, says Malbin.
Shared-use cosmetics--the testers commonly found at department store
cosmetic counters--are even more likely to become contaminated than the
same products in an individual's home, according to the 1989 FDA report.
FDA followed its 1989 report on makeup testers with a survey of
corresponding unopened retail packages. The survey found only negligible
contamination, and the agency concluded that the preservatives couldn't
handle the challenge of constant use.
"At home, the preservatives have time--usually a whole day--to
kill the bacteria that is inevitably introduced after each use," says
Bailey. "But in a store, there may be only minutes between each use.
The preservatives can't handle it."
If you really want to test a cosmetic before you buy, "you should
insist--must insist--on a new, unused applicator," says CTFA's Malbin.
She says that some companies use cotton swabs for that purpose.
Allergic Reactions
Do the preservatives themselves pose any safety risk?
According to a study of cosmetic reactions conducted by the North
American Contact Dermatitis Group, preservatives are the second most
common cause of allergic and irritant reactions to cosmetics. Fragrances
are number one. Although the study is more than 10 years old, the results
can still be considered valid today, says Harold R. Minus, M.D., an
associate professor of dermatology at Howard University Hospital. (For
more information on this study, see "Cosmetic Allergies" in the
November 1986 FDA Consumer.)
People who have had allergic reactions to cosmetics may try
hypoallergenic or allergy-tested products. These are, however, only a
partial solution for some and no solution at all for others.
"Hypoallergenic can mean almost anything to anybody," says
Bailey.
"Hypo" means "less than," and hypoallergenic means
only that the manufacturer feels that the product is less likely than
others to cause an allergic reaction. Although some manufacturers do
clinical testing, others may simply omit perfumes or other common
problem-causing ingredients. But there are no regulatory standards on what
constitutes hypoallergenic.
Likewise, label claims that a product is
"dermatologist-tested," "sensitivity tested,"
"allergy tested," or "nonirritating" carry no
guarantee that it won't cause reactions.
FDA tried to publish regulations [in 1975] defining hypoallergenic to
mean a lower potential for causing an allergic reaction," says
Bailey. "In addition, we were going to require that companies submit
information to FDA establishing that in fact their products were
hypoallergenic." However, two cosmetic manufacturers, Almay and
Clinique, challenged the proposed regulations in court, claiming that
consumers already understood that hypoallergenic products were no panacea
against allergic reactions. In July 1975, the U.S. District Court for the
District of Columbia upheld FDA's regulations, but the two companies
appealed. On Dec. 21, 1977, the U.S. Court of Appeals for the District of
Columbia reversed the district court's ruling.
What's 'Natural'?
Like hypoallergenic, "natural" can mean anything to anybody.
"There are no standards for what natural means," says Bailey.
"They could wave a tube [of plant extract] over the bottle and
declare it natural. Who's to say what they're actually using?"
Revlon, Inc., uses natural plant extracts in its New Age Naturals
cosmetics line, says Dan Moriarity, Revlon's director of public relations.
"But the base formulas are the same as our conventional
products," he says. In addition, because these products contain
fragrances, they don't fit Revlon's definition of hypoallergenic, he
explains.
Anyone who has ever had poison ivy knows that "natural" and
"hypoallergenic" are not necessarily interchangeable terms. For
example, some manufacturers of cosmetics marketed as natural products use
naturally occurring vitamins E and C as preservatives. But, according to
Alexander Fischer, M.D., author of Contact Dermatitis, "Topical
vitamin E is a potent sensitizer which can produce both delayed allergic
contact dermatitis and immediate allergic hives."
In addition, natural doesn't mean pure or clean or perfect either.
According to the cosmetic trade journal Drug and Cosmetic Industry,
"all plants [including those used in cosmetics] can be heavily
contaminated with bacteria, and pesticides and chemical fertilizers are
widely used to improve crop yields."
Safety Testing
Whether driven by altruism, liability, or the bottom line, most
companies see the need for safety testing. But safety testing can rarely
be mentioned without bringing up the controversy surrounding the use of
animals for those tests.
Many companies have begun to label their products with statements
indicating that no animals have been used in testing.
"As far as we know," says Neil Wilcox, D.V.M., director of
FDA's Office of Animal Care and Use, "what these companies do is use,
for the most part, old reliable ingredients that have been proven safe
[based on past animal data and a history of safe use] and then test the
final product on people."
"There's kind of a fine point here," says CTFA's McEwen.
"These companies that say they don't test on animals are skirting the
issue. Practically every ingredient that's used in cosmetics was at some
point tested on animals. Probably a statement like 'no new animal testing'
would be more accurate."
But what if a company wants to use a new ingredient?
Unlike drugs, FDA does not require pre-market approval for cosmetics.
However, if a safety problem with a cosmetic product arises after it's
been marketed, FDA can take action to obtain the manufacturer's safety
data on the product. Because there is not yet enough information on
alternatives to animal testing to validate their use in ensuring human
safety, FDA, at this point, would only accept animal safety data.
The most widely used, and possibly most controversial, animal test, the
Draize Eye Irritancy Test, involves putting drops of the substance in
question into the eye of an albino rabbit. Investigators then note if any
redness, swelling, cloudiness of the iris, or corneal opacity occurs. In
addition, the ability of the eye to repair any damage is noted.
"Draize may be impossible to replace with a single alternative
test," says Sidney Green, Ph.D., a toxicologist with FDA's Center for
Food Safety and Applied Nutrition.
He explains that because the Draize test measures three different areas
of the eye, replacing Draize will probably take a combination of
alternative tests, "but we've not seen that combination yet."
Wilcox explains that for FDA to approve other methods, those methods
will have to produce test results that can be reproduced in other labs. In
addition, databases will have to correlate historical animal test results
with newer lab results.
"Database development and cooperation [between industry and FDA]
is pivotal to the validation process," says Wilcox.
The cosmetics industry has taken one step towards database
development--the Cosmetic Ingredient Review. The basic purpose of the
review is to gather information from the scientific literature and from
company files on the safety of cosmetic ingredients and make that
information publicly available.
FDA's division of toxicological review and evaluation is currently
evaluating two alternatives for the Draize eye test. One is Eytex,
manufactured by Ropak Corp., Irvine, Calif., a chemical assay that
produces opacity similar to that of an animal cornea upon exposure to
irritants. The other is vertebrate cell cultures from humans and mice.
But until alternatives have been scientifically verified, the option
for animal testing must be available for new ingredients and new products,
says Wilcox. "No one wants to think of animals being used for
anything other than kindness and human companionship," he says.
"But it's important that we continue to recognize the risk to human
health if unreliable tests are used."
Dori Stehlin is a staff writer for FDA Consumer.
The Meaning of Makeup
- Draize test
- an animal test used to determine the effects of different substances
on the eyes
- fragrance
- any natural or synthetic substance or substances used solely to
impart an odor to a cosmetic product
- * fragrance-free
- products so labeled may still contain small amounts of fragrances to
mask the fatty odor of soap or other unpleasant odors
- * hypoallergenic
- cosmetics that are less likely to cause allergic reactions
- in vitro
- from the Latin meaning "in glass," in vitro tests do not
involve the use of living vertebrate animals
- lanolin
- a natural extract of sheep wool used as a moisturizer, which is a
common cause of allergic reactions but is rarely used in pure form
- * natural
- ingredients extracted directly from plants or animal products as
opposed to being produced synthetically
- * non-comedogenic
- products so labeled do not contain common pore-clogging ingredients
that could lead to acne
- parabens (methyl-, propyl-, and butyl-)
- the most widely used preservatives in the United States, commonly
used in shampoos, foundations, facial masks, hair-grooming aids, nail
creams, and permanent wave products
- propylene glycol
- the most common moisture-carrying vehicle in cosmetics other than
water.
(* There are no official, government definitions for these terms.)
--D.S.
Beauty on the Safe Side
Besides never putting on makeup while driving, consumers should follow
other precautions to protect themselves and the quality of their
cosmetics:
- Keep makeup containers tightly closed except when in use.
- Keep makeup out of sunlight; light can degrade preservatives.
- Don't use eye cosmetics if you have an eye infection, such as
conjunctivitis, and throw away all products you were using when you
first discovered the infection.
- Never add any liquid to bring the product back to its original
consistency. Adding water or, even worse, saliva could introduce
bacteria that could easily grow out of control. "If it has lost
its original texture and consistency," says McEwen, "the
preservatives have probably broken down."
- Never share.
- Throw makeup away if the color changes or an odor develops.
Preservatives can degrade over time and may no longer be able to fight
bacteria.
"We don't have a hard and fast rule on [when to throw cosmetics
out]," says McEwen. McEwen says makeup can be kept indefinitely as
long as it looks and smells all right and the consistency doesn't change.
"It would be difficult to have any kind of bacterial growth and not
have it be noticeable," he explains.
However, Janice Teal, a microbiologist who heads the product and
package safety division of Avon Products, Inc., disagrees. "Even
after the preservatives have stopped working, you may not be able to see
or smell anything different," she says.
She agrees with McEwen that there is no absolute date for discarding
various products, but says Avon recommends that consumers throw mascara
away after three months. They can keep other makeup products a few months
longer.
"Mascara is our biggest concern because of the wand," she
says. "Normally, the eye is a good barrier to bacteria, but one slip
and that wand can scratch the cornea and introduce all kinds of
bacteria."
--D.S.
Regulating Cosmetics
The Federal Food, Drug, and Cosmetic Act defines cosmetics as
"articles other than soap which are applied to the human body for
cleansing, beautifying, promoting attractiveness, or altering the
appearance."
FDA has classified cosmetics into 13 categories:
- skin care (creams, lotions, powders, and sprays)
- fragrances
- eye makeup
- manicure products
- makeup other than eye (e.g., lipstick, foundation and blush)
- hair coloring preparations
- shampoos, permanent waves, and other hair products
- deodorants
- shaving products
- baby products (e.g., shampoos, lotions and powders)
- bath oils and bubble baths
- mouthwashes
- tanning products
It is against the law to distribute cosmetics that contain poisonous or
harmful substances that might injure users under normal conditions.
Manufacturing or holding cosmetics under insanitary conditions, using
non-permitted colors, or including any filthy, putrid or decomposed
substance is also illegal.
Except for color additives and a few prohibited ingredients, a cosmetic
manufacturer may use any ingredient or raw material and market the final
product without government approval. The prohibited ingredients are:
- biothionol
- hexachlorophene
- mercury compounds (except under certain conditions as preservatives
in eye cosmetics)
- vinyl chloride and zirconium salts in aerosol products
- halogenated salicylanilides
- chloroform
- methylene chloride
Manufacturers must test color additives for safety and gain FDA approval
for their intended use.
Cosmetic firms may voluntarily register their manufacturing plants with
FDA, file cosmetic formulas, and report adverse reactions.
Cosmetics sold to consumers must bear labels that list ingredients in
descending order of predominance. Trade secrets (as defined by FDA) and
the ingredients of flavors and fragrances do not have to be specifically
listed.
--D.S.
Reports
Consumers and their dermatologists should report cosmetic adverse
reactions to:
Food and Drug Administration
Center for Food Safety and Applied Nutrition
Office of Colors and Cosmetics
200 C St., S.W.
Washington, DC 20204
(202) 205-4494
Publication No. (FDA) 95-5012
Chemical Ingredients found in
Cosmetics
At present, the cosmetic industry selects from more than 5000 different
ingredients. It's no wonder consumers can be perplexed when they see the
list. Here are some common cosmetic ingredients and their usual functions
(active drug ingredients are not included).
MOISTURIZERS function as a moisture barrier or to attract
moisture from the environment:
- cetyl alcohol (fatty alcohol) - keeps oil and water from separating;
also a foam booster
- dimethicone silicone - skin condition and anti-foam ingredient
- isopropyl lanolate, myristate, and palmitate
- lanolin and lanolin alcohols and oil - used in skin and hair
conditioners
- octyl dodecanol - skin conditioner
- oleic acid (olive oil)
- panthenol (vitamin B-complex derivative) - hair conditioner
- stearic acid and stearyl alcohol
PRESERVATIVES and antioxidants (including vitamins) prevent
product deterioration:
- trisodium and tetrasodium edetate (EDTA)
- tocopherol (vitamin E)
ANTIMICROBIALS fight bacteria:
- butyl, propyl, ethyl, and methyl parabens
- DMDM hydantoin
- methylisothiazolinone
- phenoxyethanol (also rose ether fragrance component)
- quaternium-15
THICKENERS and waxes used in stick products such as lipsticks
and blushers:
- candelilla, carnauba, and microcrystalline waxes
- carbomer and polyethylene thickeners
SOLVENTS used to dilute:
- butylene glycol and propylene glycol
- cyclomethicone (volatile silicone)
- ethanol (alcohol)
- glycerin
EMULSIFIERS break up and refine:
- glyceryl monostearate (also pearlescent agent)
- lauramide DEA (also foam booster)
- polysorbates
COLOR additives:
- Synthetic ORGANIC colors derived from coal and petroleum sources
(not permitted for use around the eye):
- D&C Red No. 7 Calcium Lake (lakes are dyes that do not
dissolve in water)
- INORGANIC pigments - approved for general use in cosmetics,
including for the area of the eye:
- iron oxides
- mica (iridescent)
HAIR DYES - phenol derivatives used in combination with other
chemicals in permanent (two-step) hair dyes:
pH ADJUSTERS stabilize or adjust acids and bases:
- ammonium hydroxide in skin peels and hair waving and straightening
- citric acid - adjusts pH
- triethanolamine pH adjuster used mostly in transparent soap
OTHERS:
- magnesium aluminum silicate absorbent - anti-caking agent
- silica (silicon dioxide) - absorbent, anti-caking, abrasive
- sodium lauryl sulfate - detergent
- stearic acid - cleansing, emulsifier
- talc (powdered magnesium silicate) - absorbent anti-caking
- zinc stearate - used in powder to improve texture, lubricates.
FDA CONSUMER, May 1994
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