Cosmetics, Nanoparticles and FOE-AUS

 Friends of the Earth - Australia (FOE-Aus) recently released a new report examining the presence of nanoparticles in cosmetics produced by such well known companies as Revlon, Max Factor, and The Body Shop.

In the press release accompanying the report, FOE-Aus noted that the labeling on cosmetics containers didn't reflect the presence of nanoparticles in the product:

“Of the ten products we surveyed, only one listed the use of nano-ingredients on the label. The government’s failure to require mandatory labeling of nano-ingredients denies women the capacity to make an informed choice about what they put on their skin.”

While this may be a legitimate complaint for the Australian regulatory agencies to consider, FOE-Aus loses much of its credibility by suggesting that the "big cosmetics companies" and nanotechnologies companies view Australian women as "guinea pigs" and by calling for

 a stop to sales of cosmetics that contain nano-ingredients, until the safety science catches up, and new laws are introduced to make companies test the safety of their products and to label all nano-ingredients,” said Ms Miller. “We are also calling for public participation in decision making about nanotechnology management”.

Considering the pace of legislation through any parliamentary body tends to be a slow process and that the issuance of regulations affecting labeling of products by the appropriate agencies would also be a long process, FOE-Aus is effectively calling for a moritorium on nano-based cosmetics for an unknown period of time.

It would be one thing if the report released by FOE-Aus supported these claims and demands. However, the report supports nothing at all.

As the report notes under the heading, "A General Note on the Study's Limitations":

This study was conducted with a limited budget and should be considered to be preliminary rather than comprehensive. Only a small number of observations of each sample were made. . . . While observations in this study of certain particle sizes does indicate that they were present in the cosmetics sampled, observations may not be statistically representative of the full sample. (Emphasis added.)

In another section of the report, we find this statement:

. . .  the particulates shown are those observed via SEM [ Scanning Electron Microscopy] and may not be representative of the average particle in the analysis. Such statistical analyses are time consuming to perform . . . and furthermore require human assisted particle identification to insure correct results. (Emphasis added)

According to anarticle in the Sydney Morning Herald, the Australian Cosmetic Trade Association has dismissed the report. Considering the limited number of products that were tested - just walk into the "Beauty Aids" section of any CVS and there will be more cosmetics than anyone can count -  and the limitations of the testing procedures that were done on them, the report that FOE-Aus presents is a weak base on which to make broad assertions about the safety of those products or to demand the shut down of an industry.




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Georgia Miller (Friends of the Earth Australia) - December 13, 2009 5:53 PM

Hi Robert and Nanotechnology Law Report

It's important to correct a significant error you have made here. FoEA are not "effectively calling for the shutdown of the Australian cosmetics industry and market for an unknown period of time". This is a serious misrepresentation of both the position of FoEA and the policy and legal implications of our call.

We are calling for cosmetics companies not to intentionally put nanoparticles into their products until such nano-ingredients are subject to nano-specific safety assessments and mandatory labelling. This is in line with recommendations made in 2004 by the United Kingdom's Royal Society. It's relevant to note that Australia's national cosmetics regulator NICNAS has already begun consultation on a proposed new nano-regulatory scheme.

Given the growing recognition that some nanoparticles used in cosmetics do pose safety risks, it was unsurprising to us that the cosmetics industry association was keen to discredit the study we commissioned and to assure the public that in fact nanoparticles are hardly used at all in Australian cosmetics. However this is highly disingenuous.

The testing commissioned by FoEA shows that nanoparticles compose a substantial portion of the particles present in many samples. As we point out, due to the limited number of samples tested, this may not be statistically representative of the total particle content of the products in question. However finding nanoparticles in 10 of 10 products tested does suggest that use of nanoparticles by the cosmetics sector is much more widespread than the industry is prepared to acknowledge.

To our knowledge this small study is the first of its kind to be released publicly. It makes an important contribution to our limited understanding of the extent of nanoparticle use in cosmetics - and shows that such use is greater than that acknowledged by the big cosmetics companies.

I question why Nanotechnology Law Report has so seriously misrepresented the position of Friends of the Earth, the policy and legal implications of our call, and the scientific legitimacy of the study we commissioned.

Georgia Miller

John Monica - January 5, 2010 1:21 PM

Ms. Miller is correct in noting that we overstated FOE-AUs' position when we wrote that: "FOE-Aus is effectively calling for the shutdown of the Australian cosmetics industry and market for an unknown period of time."

The phrase should have been qualified to indicate that any nano moritorium advocated by FOE-AU would only apply to nano-based cosmetics.

We intend to correct our article -- both online and when it appears in our quarterly newsletter. We also intend to publish a summary of FOE's position on nano-cosmetics noted in Ms. Miller's comment so that both sides of the issue are correctly and fairly represented.

We apologize for the error.

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