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Truth in Exposure: Disparity Dictates Product Safety

Contact Author Rachel Grabenhofer
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Editor's note: for additional commentary, see the Letter to the Editor.

A new study published online in the American Journal of Obstetrics and Gynecology echoes concerns in the scientific community over how exposure limits are set for given chemicals of interest in personal care products. According to the report, the effects of exposure are tested in isolation, without consideration for the disproportionate exposure some populations have to given personal care products; e.g., due to ethnic, cultural or socioeconomic preferences and practices. In 2016, similar concerns were expressed over the higher exposure levels of African-American women to certain hair and scalp products.

The current authors present this disparity as a health concern and provide evidence for the different ways in which skin, hair, beauty and feminine hygiene products are used across races and cultures. They believe the health authorities setting exposure limits should consider social factors influencing product use and the potential for cumulative effects or co-exposures.

This approach would provide a more comprehensive and realistic view of environmental influences on reproductive or other health disparities. And, taken together with exposure route, it would provide a more scientific risk vs. exposure-based assessment for toxicity—a philosophy for which the personal care industry has advocated for years. In fact, Canadian regulators are considering an overhaul of their entire cosmetics, natural health products and over-the-counter drugs categories based on this approach.

The paper follows the American Congress of Obstetrics and Gynecology committee opinion similarly emphasizing that chemicals of concern may present differential vulnerabilities based on life stage or social position. In addition, the International Federation for Obstetrics and Gynecology committee recommended health professionals write policies that secure justice, eliminating environmental racism and health inequality.

These social and scientific influences are crucial to consider; not only in consideration of today's heightened awareness over socioeconomic, cultural and other disparities, but to move the industry (and world) in an evidence-based direction.

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Letter to the Editor

In Europe, under Regulation 1223/2009 and following amendments and upgrades, since 2013, the safety evaluation of cosmetic products is made on the basis of:

  • Each material % in formula;
  • The dose of use;
  • The frequency of use and how critical the product is (depilatory products and oxidative hair colouring products are among the most critical); and
  • The age of the supposed user (with special attention devoted to products for babies or application on mucous membranes).

As such, there is a good background with which to refer, and SCCS papers published on every substance of concern are revised every 3-5 years.

The only major concern may be for potential synergies between substances, which is lacking in the evaluation mainly for the sake of simplicity and to avoid pharma-like costs, since a complete evaluation could lead to pharma-type clinical studies about pharmacodynamic, pharmacokinetic and variability of effects of the actives in the product due to these interactions.

-Ercole Tomasini

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