Between cosmetics, perfumes, personal care products and feminine hygiene products, women in the US apply an average of 168 chemicals to their faces and bodies every day, according to new research by the nonprofit Environmental Working Group.
Some of these chemicals are completely harmless, but others are endocrine disruptors, carcinogens and neurotoxins, most of which have not been independently reviewed for safety before hitting store shelves. And there is growing concern that the combined chemical burden from these products may be directly related to increased rates of reproductive issues and cancer among women.
The American College of Obstetricians and Gynecologists wrote in a 2013 report that there is “robust” evidence linking “toxic environmental agents” to “adverse reproductive and developmental health outcomes”.
Joining other leading scientific organizations, the College called for “timely action to identify and reduce exposure to toxic environmental agents while addressing the consequences of such exposure”.
But “timely action” may be a problem. Nancy Buermeyer, senior policy strategist for the nonprofit Breast Cancer Fund, says that there is insufficient research on the effects of consumer chemicals. “We don’t know enough about chemicals on any front and certainly not about how they impact women because we haven’t spent the time or energy to look at it,” she says.
Unreasonable risk
Unlike most consumables, which fall under the purview of the US Food and Drug Administration, personal care products are governed by the Food, Drug and Cosmetics Act, which requires no government review of products before they go to market. Instead, the act puts companies in charge of ensuring consumer safety.
If a customer registers a complaint about the safety of a product, the FDA can review it. But, until that point, it cannot step in. “A manufacturer or distributor of a cosmetic is legally responsible for ensuring that a marketed product is safe when consumers use it according to the directions in the labeling or in the customary or expected way,” an administration official told Guardian via email.
Another protection, the Toxic Substances Control Act (TSCA), allows the Environmental Protection Agency to investigate some consumer chemicals. However, the EPA can only step in if a chemical poses an “unreasonable risk” to public health or the environment. But this is a hard line to prove: in the 30 years since TSCA passed, the EPA has only tested about 200 of the 84,000 chemicals on the market. It has regulated five.
To make matters worse, the laws governing toxic substances may also be outdated: the Food, Drug and Cosmetics Act has not been updated since it was passed in 1938, and the TSCA hasn’t been updated since 1976.
Even if the tangled and outdated regulatory structure around consumer chemicals were reformed, consumer safety might still be at risk. The US chemical lobby is fighting hard to maintain industry self-regulation; among other things, it pushes politicians to pass TSCA reforms that would undercut stricter state regulations.
Current regulations evaluate chemicals on a per-product basis, setting acceptable limits for each chemical based on the assumption that consumers will only use one product, and will use it as directed. Unfortunately, this doesn’t reflect how consumers actually use products. The average man uses five to seven personal care products per day. The average woman uses nine to 12, and the average teenage girl uses 17, according to the Environmental Working Group study.
Gender-blind regulations
Even when consumers know which chemicals they want to avoid, they may not be able to do so because of labeling rules. For example, the FDA classifies feminine hygiene products like tampons and pads as “medical devices”, which means the companies making them do not have to disclose any of their ingredients on labels.
In 2014, nonprofit environmental health organization Women’s Voices for the Earth (WVE) commissioned independent lab testing of four types of Always pads. They found a number of chemicals – including styrene, chloroform and acetone – that have been identified as either carcinogens or reproductive and developmental toxins.
When the group analyzed a host of douches, wipes, sprays and creams, they discovered phthalates, dioxins, parabens and other potentially hazardous chemicals. Studies from Columbia University have linked phthalates to asthma and low IQ, and the National Institutes of Health (NIH) has linked dioxin to reproductive and developmental issues, as well as increased risk of cancer and heart disease. Other studies have correlated douching to a host of problems, including bacterial vaginosis, cervical cancer, and HIV transmission.
While some view many of these feminine hygiene products as unnecessary, their usage is deeply ingrained in US culture, particularly among minority women. “We hear from some women, ‘Telling me not to douche is like telling me not to shower.’ There’s no fighting that,” says Alex Scranton, WVE’s executive director.
With elimination of these products off the table, Scranton argues that adaptation is vital. “We have to make them as safe as possible to use, especially because it’s well known that the vaginal ecosystem is more sensitive and more absorbent than skin.”
But when Scranton and her team looked for information on what the chemicals in these products do to the female body when they’re vaginally applied, they found a stunning lack of information. “There’s hardly any research,” she says. “It’s incredible.”
The lack of information is not surprising: until 1992, the NIH didn’t have a vaginal health research program. In fact, it wasn’t until two women were promoted into top positions – Penny Hitchcock at the Sexually Transmitted Diseases Branch at the National Institute of Allergy and Infectious Diseases and Nancy Alexander at the Contraceptive Development Branch in the NIH Center for Population Research – that such a program was started. “They got promoted and then it was like ‘wait a minute, we don’t have that?’” Scranton said.
The 1994 NIH Revitalization Act was a step in the right direction. It required that women and minorities be included in research samples for any NIH-funded studies. These days, the NIH conducts research on vaginal health and on women’s health in general, but there is still a major research gap. This year, the NIH announced plans to draft a new policy that will require any preclinical research it funds to include both male and female subjects. The FDA also announced intentions to draft guidelines around sex differences in drug dosing recommendations.
Closing the gender gap in health
There are efforts underway to reform the Food, Drug and Cosmetics Act and TSCA. Currently, two competing TSCA bills are making their way through the Senate, one authored by Senators Tom Udall and David Vitter, and the other by Senators Barbara Boxer and Edward Markey.
Competition between the two bills is fierce, and even nonprofits appear to be divided in their support. The Environmental Defense Fund backs Udall-Vitter, while public health nonprofits like EWG, Breast Cancer Fund, and the Natural Resources Defense Council claim that the bill is too heavily influenced by the chemistry industry. According to them, it attempts to preempt state laws that regulate chemicals.
The consumer chemicals industry is equally divided: the American Chemistry Council backs Udall-Vitter, while the Personal Care Products Council backs Boxer-Markey. Both industry groups have issued strong statements in favor of reform, but their critics have accused them of backing federal initiatives in an effort to weaken state regulations.
As the debate rages, it highlights a lack of public knowledge – and sometimes sexism – surrounding regulations.
In reference to the Food, Drug and Cosmetics Act, Heather White, executive director of Environmental Working Group, says: “There is a movement on the Hill to reform it now, but part of the reason it hasn’t been, I think, is that it’s seen as a women’s industry and somewhat silly and not something that needs to be addressed.”
Stacy Malkan, co-founder of the Campaign for Safe Cosmetics, says that 10 years ago, a debate over phthalates – one class of chemicals of concern – focused on the impact that they have on young boys. “People would say ‘oh well, it affects boys, so why do we have to regulate it for women?’” she says.
“And I had to explain over and over again – and still do – that boys spend their first months in women’s bodies, and that’s when they’re most vulnerable.”
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