Breast cancer. Genital abnormalities. Distortion and damage of genetic
Common ingredients in cosmetic products have been linked to these hazards.
As further research is conducted into the long-term and cumulative effects on
cosmetics users, their children and the water supply that products are washed
off into, more questions arise. Not that you'd know it by listening to the cosmetics
An important underlying issue is that the industry is largely self-regulated.
While interstate trade in "adulterated or misbranded cosmetics" is
U.S. Food and Drug Administration (FDA) does not review new cosmetics before
they are marketed and cannot order recalls of hazardous cosmetics. "Cosmetic
firms are responsible for substantiating the safety of their products and ingredients,"
reads the FDA's own explanation.
The industry's trade group, the Cosmetic,
Toiletry, and Fragrance Association (CTFA), likes this hands-off approach.
CTFA has 600 member
companies, including Aveda, Clairol, L'Oréal, and Unilever, and standing
committees on government relations, public affairs, and international issues.
says CTFA promotes "industry self-regulation and reasonable governmental
requirements." But reasonable to who?
Health and environmental organizations are increasingly seeing the status quo
as unreasonable and untenable. In 2002, the Breast Cancer Fund, Environmental
Working Group, National Black Environmental Justice Network, and others launched
the Campaign for Safe Cosmetics.
Its goal is the phase-out of cosmetics ingredients linked to cancer, birth defects,
and other health problems. In May 2006, Friends of the Earth and the International
Center for Technology Assessment petitioned
the FDA to monitor products with nanoparticle ingredients, including more than
100 cosmetics and sunscreens. Due to their incredibly small size, nanoparticles
can enter tissues and cells and cause biochemical damage.
CTFA seems nervous. In its 2005 annual
report, CTFA chair Marc Pritchard warned, "It is clear that our industry
is at a crossroads in the areas of safety, self-regulation, and global harmonization,
and will require further action on our parts to lead to positive changes."
He added that "activist groups" are "attacking us on several
fronts and taking their messages to consumers."
But CTFA has some potent tricks up its sleeve. In December 2005, The Hill reported
that CTFA was on a "hiring spree," bringing aboard several new lobbying
and public relations staffers, including Representative Mike
Oxley's (R-Ohio) son, Elvis, and Kathleen Dezio from the American
Beverage Association. In May 2006, CTFA added a new vice-president of communications,
Lisa Powers. Powers told PR Watch that her "primary objective is to strengthen
the message about product safety."
On June 1, 2006, CTFA shmoozed members of Congress with its "Fragrance
Day" on Capitol Hill. The event opened with "a VIP reception, by invitation
only, for Congressional Members including members from the Committee on Energy
and Commerce," followed by an "open house for members and staffers,"
according to a CTFA press
Whether CTFA will be able to neutralize the mounting health concerns and regulatory
pressures faced by the cosmetics industry depends largely on whether such lobbying
and PR efforts go unchallenged.
Chemical Terrorists Are after Your Mascara
Lexi Shultz estimates that she uses 20 or more cosmetic products -- including
soap, shampoo, and lotion -- on a daily basis, even though she has "personal
concerns about how safe they might be." So, when she saw an email about
a Washington DC focus
group on cosmetics, she applied to take part in it.
The January 2006 focus group was conducted by Luntz Research, the polling and
political consulting firm founded by Frank
Luntz. Luntz is probably best known for his polling to develop the 1994
Republican "Contract with America," his work to reframe the estate
tax as the "death tax," and his use of so-called "dial technology"
in focus groups. The idea behind the dials, as Luntz explained
to PBS, is that they allow focus group members to immediately and anonymously
respond to "every single word, every single phrase."
In the cosmetics focus group, Shultz and 27 others were shown a series of video
clips, and asked to turn their dials to the right if they felt positively about
what was shown and to the left if they felt negatively. The first clip featured
Environmental Working Group representatives raising concerns about the use of
chemicals called phthalates in cosmetics. Some phthalates have been linked to
reproductive abnormalities in animals. The Campaign for Safe Cosmetics' first
report, "Not Too Pretty: Phthalates, Beauty Products and the FDA,"
found that 52 of the 72 cosmetics, deodorants, and perfumes tested contained
Every other video shown during the focus group was from the cosmetics industry's
point of view. In one, an unidentified person claimed that "chemical terrorist
groups are trying to frighten you" by claiming that cosmetics are not safe.
Other negative terms applied to health and environmental organizations were
"opposition groups" and "questionable groups." The phrase
science," often employed to muddy policy debates, was used repeatedly.
"The industry messages were in attack mode," Shultz told PR Watch,
but it didn't play well. "The stronger the language in a video clip, the
more negative the reaction from the focus group." Another major theme,
choice, also backfired. In response to an argument that adults should be allowed
to make their own decisions about cosmetic products, as they do about alcohol
and tobacco, participants asked, "Didn't the tobacco
industry lie to us for years?"
What appealed to the focus group were independent experts, government agencies,
and review processes overseeing and ensuring the safety of cosmetic products.
One video featuring a woman epidemiologist received especially high ratings.
Participants also expressed interest in doing their own research. This was explored
throughout the session, with the moderator asking where participants would do
their research and who they would believe. At one point, participants were asked
to fill out worksheets describing a website with information on cosmetics ingredients,
to be launched in 2007.
The client paying Luntz Research to conduct the focus group was not identified,
but CTFA's Lisa Powers confirmed that the association had commissioned focus
groups, "to find out what the issues are that are out there and how well-known
CTFA was." She couldn't comment further on the subject, she said, as the
focus groups were held before she joined CTFA.
Mirroring Activist Campaigns
The parallels between what was discussed during the cosmetics focus group and
CTFA's new "consumer-oriented industry initiatives," announced at
the association's annual meeting in March 2006, are striking. The
initiatives include "a consumer beauty information web site,"
described by CTFA as "the definitive place to go for consumers seeking
information about the science behind cosmetic products and ingredients."
Also on the list is "a new consumer commitment code," to "reaffirm
the industry's commitment to safe products."
As described in a May 2006 letter to CTFA members, the "Consumer Information
Website ... will use the latest technology to provide consumers with safety
information about cosmetic products and ingredients, as well as educational
information on how the industry conducts its safety reviews and testing."
Powers described the website as "a critical piece" of CTFA's work.
She said that CTFA is currently "collecting significant data" for
the website, which is expected to go public in early 2007.
With regard to CTFA's new "Consumer Commitment Code," the association
is giving "all CTFA member companies" a deadline of January 1, 2007,
to "certify compliance," according to the May letter. "Companies
that are compliant with the code will receive special recognition on the CTFA
website and can promote this to customers and vendors," it adds.
The code directs companies only to use ingredients and market products that
have sufficient safety information, to report "serious or unexpected"
adverse reactions to the FDA, and to make ingredient and product safety data
available to the FDA. Given that these are very minor changes to the current
system, it's fair to ask whether the code's real goal -- or, at least, its effective
outcome -- might be to promote cosmetic products and companies as compliant,
under a system defined by and for the industry itself.
After all, independent standards have a way of threatening the status quo.
Europe is a case in point. Since September 2004, the European Union has
banned more than 1,200 substances from cosmetic products, including some
phthalates and other chemicals still allowed in U.S. cosmetics. By the end of
2006, the European Union is expected to enact more comprehensive legislation
requiring chemical producers and users to provide basic data on potential health
and environmental hazards before products can be sold. (Not surprisingly, the
Bush administration worked with the American
Chemistry Council and other industry groups in an attempt to
derail the pending European legislation, which they characterized as too
"costly, burdensome, and complex.")
While CTFA, like other trade associations, promotes "industry self-regulation,"
that regulation must be perceived as rigorous enough to avoid significant criticism
or government action. That's where CTFA's industry initiatives come in. Ironically,
its initiatives mirror those of the activist Campaign for Safe Cosmetics. "What
can we say -- imitation is the highest form of flattery," Stacy Malkan
of Healthcare Without Harm commented dryly.
As CTFA builds its own informational website, the Campaign for Safe Cosmetics
has "Skin Deep."
Launched in 2005 and hosted by the Environmental Working Group, Skin Deep draws
on 37 government, academic, nonprofit, and professional reports and databases.
The interactive site matches toxicity information and regulatory status on more
than 7,000 ingredients with nearly 15,000 cosmetic and personal care products.
Website visitors can determine the "safety score" of the products
they currently use, browse by product type or brand name, or find the lowest-risk
products that meet their needs.
As CTFA holds seminars to explain its new code to member companies, the list
of signatories to the "Compact for the Global Production of Safe Health
and Beauty Products" is growing. The Campaign for Safe Cosmetics drafted
the Compact in 2004, based on European standards. Companies that sign the
Compact agree to inventory the chemicals they use, replace chemicals banned
by the European Union with safer alternatives within three years, and publicly
report on their progress. As of March 2006, more than 300 cosmetics companies
-- mostly smaller ones -- had signed on. "Despite repeated requests, multinational
companies such as L'Oréal, Revlon, Estée Lauder, Gap, Avon, OPI,
and Procter & Gamble have refused to sign the Compact," notes a Campaign
for Safe Cosmetics press
Lipstick on A Pig
While CTFA may seem to be on the defensive, one advantage the association has
is its past experience fighting -- and at least partially winning -- similar
In the 1980s and 1990s, the cosmetics industry came under intense scrutiny
for its animal testing practices. Many people were disturbed by the outmoded
and often extreme methods used, such as putting massive amounts of cosmetics
into animals' eyes or stomachs. By 1991, ten states were considering legislation
to limit the use of animals in cosmetics testing.
from an April 1987 meeting of the Chemical Manufacturers Association (CMA, now
called the American
Chemistry Council) read: "The committee discussed the various animal
rights bills pending that would restrict the use of animals for health effects
testing. It agreed to gather more information on policies and positions that
other trade and professional groups have adopted. The Health and Safety Committee
recommended that CMA allow the Cosmetic, Toiletries, and Fragrance Association
[sic] to take the lead advocacy role on this issue."
In 1989, CTFA asked its member companies to help it raise $1 million to combat
-- in the words of then-CTFA president Ed Kavanaugh -- "a very negative
and ... very dangerous campaign that is being conducted in the name of animal
rights." According to Women's Wear Daily, CTFA retained the services of
Harrison, who is often considered the pioneer of "environmental public
relations," or greenwashing. (When asked by PR Watch, CTFA's Lisa Powers
said the association is currently working with multiple outside PR firms, but
declined to name them.)
According to its
website, CTFA's early efforts to defuse the animal testing controversy included
establishing a task force to "explore alternative testing procedures;"
sponsoring a symposium on animal testing, to foster "an open exchange of
opinions and ideas" between the industry and animal rights activists; and
awarding grants to the Johns Hopkins School of Hygiene and Public Health, to
develop alternatives to animal testing. Later efforts, including lobbying and
newspaper op/ed campaigns, were focused on the states considering animal testing
After the California legislature passed an animal test ban in 1990, CTFA pulled
out all the stops. Working with former Surgeon General Dr. C. Everett Koop --
who was at the time also helping
PR firms defend pesticides and recombinant bovine growth hormone -- CTFA won
a gubernatorial veto of the California bill, twice.
Kathy Guillermo had a front row seat for much of this heated debate. She was
the director of the Caring Consumer Campaign of the People for the Ethical Treatment
of Animals (PETA) from 1989 through 1993. She told PR Watch that several aspects
of CTFA's response to animal testing concerns were misleading.
"The industry adapted the tests so that, for example, fewer rabbits were
used in the eye irritation tests and a smaller percentage were poisoned to death
in the lethal dose tests," explained Guillermo. "They were merely
variations on the same tests, but the CTFA, by using a narrow definition, claimed
that most companies no longer used the Draize [eye irritation] and [lethal dose]
tests. They knew this would be taken to mean that companies weren't putting
chemicals in animals' eyes and force-feeding chemicals, when they were still
doing this." She also questions the impact of CTFA's grants to Johns Hopkins,
saying that the university's Center for Alternatives to Animal Tests "has
been little more than an apologist for the animal testing industry -- not a
single in vitro (non-animal) test now in use has emerged from the center."
Not surprisingly, CTFA tried to discredit PETA, claiming that the group "was
interested only in publicity and donations," said Guillermo. She told PR
Watch that she even received phone calls from "people identifying themselves
only as private investigators hired by the cosmetics industry. They seemed rather
obvious in their attempts to gather some sort of 'inside PETA' information that
might be used to damage our reputation -- questions like, 'What about your off-shore
bank accounts?' and other nonsense."
But CTFA's negative rhetoric didn't stop there. The association "claimed
that companies that had banned animal tests were 'dishonest' because they used
ingredients that had been tested on animals in the past," according to
Guillermo. "This was just silly. We were aware that most chemicals had
been tested on animals. We applauded companies that chose to let this remain
in the past rather than continue it."
Guillermo advises health and environmental groups now challenging the cosmetics
industry "not to be intimidated by the CTFA, or any other industry group.
The fact that it mounted a campaign against PETA and our work was evidence that
they were running scared. ... For PETA it was more effective to go directly
to the consumer and not spend huge amounts of time on worry about what the CTFA
Compared to CTFA's past efforts to defuse animals rights activism, the association
is now doing more to "go directly to the consumer" with its own messages
downplaying health dangers and confusing the oversight issue. But the current
concerns may hit closer to home for many. "Infants imbibing breast milk
may also be sucking down a high dose of phthalates," reported
Environmental Science & Technology in July 2006.
Advocating that cosmetics companies reformulate their products to exclude ingredients
known or strongly linked to health problems is not "chemical terrorism"
or "junk science." It's common sense, no matter how hard CTFA claims
Diane Farsetta is a senior researcher at the Center
for Media and Democracy.
Read from Looking Glass News
filled with chemical soup, says study
Walking, Talking Toxic Waste Dumps
Seen From Antibacterial Soap Chemicals
59 ingredients in a fast-food strawberry milkshake
Common Household Toxins
"New car smell" includes toxins